### for exemption / rule **- ma**  **king**

**Cont act information:**  Brian Gaudet, d.b.a. S trategic Designs 39 T if fany Cir
. Millbury, MA

01527 bgflyer@icloud.com 508 - 754 - 5664 **This is an exemption request pursuant to FMRA Section 333 and Part 1**  **1 of the F** **AA Reform**  **Act of 2012 for Mr** **. Brian Gaudet, d.b.a., S trategic Designs** 
. The proposed exemption, if granted, would allow S trategic Designs to conduct commercial operations of sma ll unmanned aircraf t systems (“UAS”) meeting or exceeding all of the operational and safety requirement s Congress has set forth in Section 333. Petitioner is an aerial service and technology comp any that plans to exploit the cap abilities of Unmanned Aeri al Systems to of fer a multitude of services, including:

- Aerial surveying / inspections - Remote sensing - Te lecommunications - Agriculture - Aerial filmmaking and photography - Energy systems inspections and asset management / wind turbine inspection

- Construction site inspections and monitoring - Wi ldlife and forestry monitoring

- Educational and research operations - Pipeline / cell tower inspections **Pilot in Command (PIC)** The pilot in command will be the owner of S trategic Designs, Mr . Brian Gaudet . Mr . Gaudet received his airman’ s Private Pilot Certificate in 1977, number 3638364 and holds a current F AA - issued 3rd class airman medical certificate has a current bi - annual fight review . Mr . Gaudet has logged over 150 hours in single engine aircraf t. M r. Gaudet is also currently a part owner of a Cessna Cardinal 177B which he flies regularly as PIC. Mr
. Gaudet is current for both day and night operation as PIC. Petitioner will comply with the applicable procedures and requirement s st ated in § 91.103. Sp ecifically , the PIC will t ake all actions including reviewing weather, flight battery requirement s, aircraf t performance data, and landing and takeoff distances before initiation of a flight. The PIC will also account for all relevant site - specific condi tions in their preflight procedures.**Petition Exemption Summary :** 

Regulations from which the exemption is requested:

- 14 C.F .R. Part 21 (H)

- 14 C.F .R. Part 27

- 14 C.F .R. 45.23(b)

- 14 C.F .R. 61.23(a) and (c),

- 14 C.F .R. 61.101(e)(4) and (5)

- 14 C.F .R. 61.1 13 (a) - (b)

- 14 C.F .R. 61.315(a)

- 14 C.F .R. 91.7(a)

- 14 C.F .R. 91.103(b)(2)

- 14 C.F .R. 91.105

- 14 C.F .R. 91.109

- 14 C.F .R. 91.1 19(c)

- 14 C.F .R. 91.121

- 14 C.F .R. 91.151 (a)(1)

- 14 C.F .R. 91.405 (a)

- 14 C.F .R. 91.407 (a) (1)

- 14 C.F .R. 91.409 (a)(1) - (2)

- 14 C.F .R. 91.417 (a) - (b) **Description of UA S and Equivalent Level of Safety**  The primary UAS system that will be used is the **DJI Inspire 1** quadcopter (model T600). The UAS will be safely operated in the NAS by maint aining line of sight visual contact, flown only during daylight, and less than 400f t above the ground. Flight s will be operated at a lateral distance of no less than 100 feet from any persons or property not associated with the operation. Additional safety features on the DJI Inspire 1 include return to home functionality when GPS is available and failsafe technology that return the aircraf t to the takeof

f point if the batteries run low
. Additionally , the max flight time for the UAS will be limited to maint ain a reserve of 25% battery power
. At all times, the UAS will be operated in accordance with the safety and operational requirement s of the manual (see link below .) The specifications for the UAS **DJI Inspire 1** are as follows: **Weight:** 2935 g **Diagonal Size:** 438 x 451 x 301 mm **Max As**  **cent S peed:**  5 m/s **Max Descent S peed:**  4 m/s Max S peed: 22 m/s (no wind)The Petitioner has supplied the following additional information on the **DJI**

**Inspire 1** UAS: **Inspire 1 Specs** http://www.dji.com/product/inspir e - 1/spec **Inspire 1 Quick Start Guide** http://download.dji
- innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Sta rt_Guide_v1.4_en.pdf **Inspire 1 User Manual** http://download.dji
- innovations.com/downloads/inspire_1/en/Inspire_1_User_Man ual_v1.4_en.pdf **In spire 1 Safety** 

**Guidelines** http://download.dji
- innovations.com/downloads/inspire_1/en/Inspire_1_Safety _G uidelines_en.pdf **Inspire 1 Maintenance Manual** http://download.dji
- innovations.com/downloads/inspire_1/en/Inspire_1_Maintena nce_ManualV1.0_en.pdf **UA S Op**  **erations** Preflight would include checking the operation of the UAS to include the battery in both the transmitter and the UAS, the condition of the body of the UAS and it s propellers. Updates to the firmware will be done as they become available and mainte nance will be performed pursuant to the manufacturers recommendations. The area in which the drone will be flown will be checked for power lines, antennas, and other obstructions. The weather conditions will be monitored throughout the flight. Wind conditi ons will be reviewed and the UAS will only be flown in daylight. As the pilot, Brian would ensure that he is safe to operate the drone as though he were flying in the aircraf t himself. **UA S Operating Parameters**  The petitioner st ates that all flight s will b e operated within visual line of sight (VLOS) of pilot, in daytime VFR flight conditions and all operations will be conducted with the assistance of a second spotter/observer . T he UAS flight s will be limited to a maximum altitude of 400 feet AGL. Altitude is accurately measured by GPS. The petitioner further st ates that an operator will ensure that only consenting production personnel will be allowed within 100 feet of the UA operation, and UAS will be kept at least 100’ from any inhabited structure. Genera llythe petitioner ’s UAS will be operated in rural or suburban areas that will permit significantly larger safety zones. F lights would be conducted within the borders of the the United S tat es. Flight S tandards District Of fices (FSDOs) will be notified as required prior to operations to describe intended coordination for proposed operation(s). Petitioner will obt ain an Air Tr affic Organization (“A TO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting any operations under this grant ofexemption. In fulfilling it s requirement s under the COA, Petitioner will be required

to request a NOT

AM not more than 72 hours in advance, but not less than 48 hours prior to the operation. Petitioner ’s UAS will remain clear and yield the right of way to all manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, p arasailing activities, and gliders / hang gliders). Petitioner will not conduct UAS operations within 5 nautical miles of the geographic center of a non - towered airport unless a letter of agreement with that airport’s management is obt ained and the operation is conducted in accordance with a Notice to Airmen (“NOT AM”). **Safet y**  **and Benefit s of the UA**  **S** The petitioner will be using the UAS in a variety of applications that generally require expensive full - size manned aircraf t to complete. Small, light, unmanned aerial vehicles of fer a myriad of benefit s over the use of full - sized manned aircraf t for electric power line inspection, o il/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few . Replacing significantly larger manned aircraf t carrying crew and flammable fuel with small UAS carrying no p assengers or crew creates a much greater margin of safety for the pilot s and crew . By granting Petitioner ’s requested exemptions, the F

AA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Petitioner is committed to promoting the UAS research ef forts of policymakers including the F AA, NASA, DOD and DARP A by sharing dat a from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the F AA has good cause to grant this Petition. **Conclusion** For the foregoing reasons, the exemptions requested herein should be granted and Petitioner should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the F AA. Thank you for your consideration. Sincerely, Brian Gaudet, d.b.a. S trategic Designs Owner/Pilot 39 T if fany Cir
. Millbury, MA

01527 bgflyer@icloud.com 508 - 754 - 5664