January 5, 2016 FAA Docket Management Facility U.S. Department ofTransportation 1200 NewJersey Avenue, SE West Building, Ground Floor, Room W12-140 Washington, DC 20590

Dear Exemption Manager, 

### .. '

. '-' 1;

I am submitting my Petition for Exemption for Unmanned Aircraft Systems operations. ...\,,**~, r-~**  

### > _j**·~r**

I am a licensed Light Sport Pilot (copy of license enclosed) and hold a Repairman Light Sport Aircraft as also shown on my license. Iwas a LS-DAR (Light Sport Designated Airworthiness Representative from April 2007-2010. I have over 900 hours in Experimental Light Sport Powered Parachutes and have been flying since 1999. I understand the importance ofoperating a UAS in a safe manner. My request is for a waiverofthe sections identified below in an effortto operate a UAS for commercial photography and video. Operating a UAS would offerour potential customers a unique view pointfor their photos and video. My request is to operate a UAS for commercial purposes to record aerial video and photography of real estate, general photography, and special events. I am seeking exemption of: Section of 14CFR: parts 21 Subpart H, 27, 45.23(b), 45.27(a), 61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.319(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). If I have erroneously omitted any other relevant section or, overstated any relevant section for my intended operations, please feel free to suggest the missing oroverstated section(s). Suggested Public Federal Register Summary: "The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) under the new FAA "Summary Grant" approach, announced April 9th, 2015 http://www.faa.gov/news/updates/?newsld=82485that will help speed up Section 333 exemption approvals for many commercial UAS operators priorto finalizing the small UAS proposed rules published this past February. It is my understandingthatthe FAA will still review each Section 333 petition individually. However, It is my hopethatyou find thatthe enhanced safety achieved using an unmanned aircraftwith the specifications described bythe petitionerwhich carries no passengers or crew, ratherthan a manned aircraft ofsignificantlygreater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find thatthe UAS operation enabled bythis exemption is in the public interest. I am hopingthatthe agency will accept my particular petition, and include it in the next summary grant, and issue me an exemption on the presumption thatthe FAA has "already granted a previous exemption similartothis request".

### . 

# ..

Apparently, the new interim policy includes thegranting ofa Certificate ofWaiver or Authorization (COA) forflights at or below200 feet to any UAS operatorwith a Section 333 exemptionfor aircraftthatweigh less than 55 pounds, operate duringdaytimeVisual Flight Rules (VFR) conditions, operate within visual line ofsight (VLOS) ofthe pilots, and stay certain distances awayfrom airports or heliports such as 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airportwith a published instrumentflight procedure, but not an operational tower; or 2 NM from an airportwithout a published instrumentflight procedure oran operational tower; or 2 NM from a heliport with a published instrumentflight procedure. It is also understood thatthe "blanket" 200- foot COA allows flights anywhere in the country except restricted airspace and other areas, such as majorcities, where the FAA prohibits UAS operations. UAS Description: I am asking for an exemption fora UAS up to 55 pounds because Iforecast I will be using a craftthat will be flown operationally, weighing less than five pounds and more specificallythe DJI Phantom models as well as the Yuneec Q500 model, and will be qualified as a UAS. In the event a loss ofcommunications occurs the craft will rise upverticallyto a safe height before beginning an automatic return to homefunction. The control signal may be reconnected in flight and the pilotcan take over safe operations again ifcommunication is reestablished. However in the case ofa GPS failure the craft will be able to be manually flown to a safe landing bythe pilot. The craft operates electrically, carries no flammable fuel, and has an integrated GPS pilot system. I understand the importance ofconducting safe flight operations and planning flight paths which minimize flights over crowds. Flights will end when battery reserve reaches no less than 25 percent. Operations will not occur under IFR conditions. In addition, preflight and post-flight checklists and UAS examinations will help detectany abnormalities priorto flight and afterflight. Any UAS unable to satisfy safetychecklists will be removed from service until the issue can be resolved. Grantingthis request would not adversely affect safety since operations would be in accordance with current UAS rules. Section 333 Compliance and Appropriateness: Based on the size ofthe craft, experience ofthe pilot, and operational goals, this request appears to be well suited for approval using the current criteria outlined in Section 333 ofthe FAA Modernization and Reform Act of2012 (including new interim policies)

7813 Larchwood St Dublin, OH 43016 614-792..0707 Email: dreamflights@columbus.rr.com**·--·~-...-·** 

### UNITEDSTATESOFAMERICA

## Xlc~·/ 

# /ft
O£P.AlllKJITCF TRAICSI'CIItA'IlCN • F£Da1ALAWI'IMaADIIila1RA,_**~">** f'/NAME •

EDDY LEE MCKINLEY
VADDRESS\t_,_

_ 

# ___.l

!11\i!O'IAUTY USA _J- \

ll DATE OF iSSUE

XIII LIMITAnartS SPORT**~**I'OIIii'E1ttni'ARACHlrl!! LA11D. H<X.DER DCIESNOTWI'TICAORI:CUII<I!!!Ifi'S.

"SIGNA'I'URI! OF HOLDE,R'-,, 

## J

·. -:f

" " 

# "

## . 

# .

U.S. Department of Transportation Federal Aviation Administration 

### April 3, 2007 Mr. Ed McKinley DARF-831030-CE 7813 Larchwood St. Dublin, OH 43016 DearMr. McKinley: Vandalia Mfg. Inspection 

### District Office (MIDO) 3800 Wright Drive Vandalia, OH 45377 Phone: 

### 937-898-3991 FAX 937-898-8717



### We are pleased to inform you that your appointment as a Light Sport Designated Airwmthiness Representative (LS-DAR), perTitle 14 Code ofFederal Regulations (14 CFR) section 183.33 has been approved. This letter serves as your Certificate ofAuthority. This Certificate of Authority should be retained for your use and should be safely filed where it is available to you and the FAA. Your FAA Fonn 8000-5, Certificate ofDesignation, is also enclosed and should be displayed in your office. DESIGNATION CERTIFICATE NUMBER: DARF-831030-CE FIXED BASE OFOPERATION: 7813 Larchwood St DATE OF DESIGNATION: DESIGNATION EXPIRATION: Dublin, OH 43016 April3, 2007 November 30, 2007 This authorization is subject to certain functions and limitations as described below. AUTHORIZED FUNCTIONS AND LIMITATIONS: 1. Function Code 47- Issue recmTent/original and replacement special airworthiness certificates, experimental, for the purposes ofoperatingU.S. registered light-spmt aircraft. LIMITATIONS: Powered-Parachutes <:onstructed ofmetal, tube and fabric, ortube and sail. 2. Function Code 48

- Issue recurrent/original and replacement special airworthiness certificates, for U.S. registered light-spott category aircraft and special flight permits for lightsport category aircraft production flight-test operations. LIMITATIONS: Powered-Parachutes constructed ofmetal, tube and fabric, ortube and sail. *************************NOTHING FOLLOWS**************************** 

### Please report any designee activity to this office on a quarterly basis. This repmt is due to your managing office bythe fifteenth (15th) of: March; June, September and December ofeach year.

# ,, ' 

# . ...

This authorizationwill expire onNovember 30,2007, unless a writtenrequest for renewal is submitted to the VandaliaManufacturing Inspection District Office. This should be accomplished not less than 60 days prior to the expiration date. This writtenrequest for renewal should containthe information specified inFAA Order 8100.8( ). Designee appointments are evaluated priorto renewal forproperperformance, activity, and determination ofFAAneed. FAA Order 8100.8( ), Designee Management Handbook, Chapter 10 provides information for the renewal process. Designee renewal is accomplished through an automated selection, appointment, andrenewal (SAR) system for AIRdesignees. Sincerely,

# ())~ Dorsey, M g

MIDO, CE 8

OFFICE DATEEXPIRES INSPECTOR'S SIGNATURE 

## 2