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Exemption	Request	for	FAR	333 Larry	Bossone MCS	Communications 27	Bodine	Rd. Berwyn,	PA	19312 (610)	648 - 0385 mbossone27@gmail.com MCS	Communications	request	to	s eeking	exemptions	from	the	following	FAR	Parts in	title	14	Code	of	Regulations
. Purpose:	Using	Remote	Control	Helicopter
– under	4 .4 lbs (2	kg.) .		for	viewing private	properties	for	sales,	evaluations,	mortgage	applications,	maintenance	and related	business	intentions Following are	Parts	seeking	an	exem ption with	abbreviation	of rules	and	alternate proposals	for	exemption Part	21	Procedural	requirements	for	fixed	wing	and	changing	design	approval production	approvals,	airworthiness	certificates	and	airworthy	approval REASON	REQUEST	EXEMPTION:	Size,	weight,	speed,	limited	operating	area See	enclosed	Specifications	** meets	the	equivalent	level	of	safety	under	14	CFR	part 21	Subpart	H. 45.23	(b)	Registration	numbers REASON	REQUEST	EXEMPTION:		Size	of	UAV	makes	it	impossible	to	have	2” lettering. ALTERNAT E PROPOSAL:	Lettering	designed	in	accordance	with	14	CFR	part	47	and having	identification	(N	number)	markings	in	accordance	with	14	CFR	part	45 (c) as large	as practicable. 61.133	Commercial	Pilot.		FAA	has	already	granted	exemptions for	UAV	operations
. Private	pilot	license	is	deemed	sufficient	for	operation	of	UAV
. ALTERNATE	PROPOSAL:	Operator	will	be	Private	Pilot	with	currency	as	re quired	by 14	CFR	61:	56;	61: 57,	as	well	as	requirements	under	14	CFR	61:51(b)2

91.7	No	person	may	operate	aircraft	unless in	airworthy	condition ALTERNATE	PROPOSAL (see	Assembly	and	Flight	Cautions	taken	from	Phantom manual (Proprietary
– Not	for	Publication) 91.9	(b)	Flight	Manual		(see Flight manual - Propriatary) 91.103	Preflight	Actions : Alternate	Proposal (See Checklist : P ilot	will	perform	all	functions	before beginning flight 91.109 Dual	Controls	for	flight	instruction - Flight	training	will	be	accomplished	at	remote	field approved	by	owner of	location
. No	persons	allowed	within	3 00	feet	of	operation	except	those	required	for	safe operation	of	training. (see	training	syllabus) 91.119	Minimum	Safe	Altitudes:		All	flights	will	be conducted	below	400	feet	AGL. Will	operate	only	in	safe	areas away	from	public	and	traffic,	thus	providi ng	a	level	of safety	at	least	equivalent	to	or	better	than	full	size	of	aircraft currently	used	for these	operations with	weights	of over	5000 lbs.		AUV gross	weight will	weigh	under 4 .4 lbs
. ,	carry	no	liquid	fu el	and	operate	under	speeds	of	3 0	mph. 91.121 Altimeter	Settings: Regulation	is	inapplicable	for	this	type	aircraft.	UAV utilizes	a	GPS	with	barometric	sensor. 91.151	(a)	Fuel	Requirements
– Land	with	minimum	25 %	battery	power (indicated on	transmitter	screen	and	video	monitor) 91.203	(a)	Appropriate airworthy certificate (See certificate	DJI	Specifications Phantom	2 [Confidential]) 91.405 Maintenance	Required Alternate	Proposal: Pilot	will	inspect aircraft using	DJI see Phantom	Pilot	Preflight Checklist	(Confidential)
. Pilot	will	perform	minor	maintenance	such	as	replacements of	propellers,	minor	adjustments,	weights	and	balance.		Major	modifications	or repairs	will	be performed	by	manufacturers	representatives or	persons	skilled	in electronics	of	Phantom	2
. MCS	Communications - FAR	333	Exemption Request3

91:409	(a)	(1)	(2)	Inspections	(See	above) 91.417	Maintenance	Records
– Owner	will	keep	log	of	all	maintenance	performed.

MCS	Communications request exemptions	for	the	above	items	for	the	purpose of operating	a	UAV	for	close	set	fil ming	for the	motion	picture	and	television	industry. The	flights	will	be	below	400	feet	AGL	and	not	exceed	a	ground	speed	of	40	knots. The	aircraft will	be	the	DJI Phantom	2. Aircraft will not	exceed	4 .4 pounds	(see specifications ). The	aircraft	will	be	operate d within	visual	line	of	sight	of	the	PIC	at	all	times.		All operations	will	consist	of	a Phantom	operator	and separate	camera - pers on	to operate	the	camera	gimbal .		All	person s	shall	be	able	to	communicate at	all	times while	aircraft	is	operating. The	a ircraft	will only	operate	in	a	“sterile	area” not	be	operating	within	3 00	ft.	of non - participating	persons	except	those	consenting	to	be	involved	and	neces sary for	the	production. An	aviation	safety	inspector may	approve a	smaller	radius consistent	with safety	requirements. MCS	Commun ications	will	submit	a	written	“Plan	of	Activities ” to	FSDO	3	days before	the	proposed	shoot. MCS	Communications	will	obtain	the	consent	of	all	persons	involved	in	the	filming and	insure	that	only	consenting	persons are all owed	within	100	ft.	of	the	flight operation	and this	radius	may	be	reduced based	upon	an	equivalent	level	of	safety. However,	the	advanced	permission	of	the	relevant	FSDO,	operation	at	closer	range can	be	approved. Written	and/or	oral	permission	from	the relevant	property	holders	will	be	obtained. MCS	Communications - FAR	333	Exemption	Request4

A	briefing	will	be	held	before	each	flight.		All	persons	involved	in	the	filming	must	be present	and	understand	the	purpose	and	parameters	of	flight. The	aircraft	will	be	available	with	an	emergency	return	to	home	condition	in	case	of failure	of	all	components. Using	a	UAV for	companies	involved	in	sales,	maintenance,	inspection	and evaluation	of	property,	provides	a	safer and	more	economical method of	obtaining information
. Pictures	from	a	UAV	would	allow	inspections of	the	construction from areas not	available	at	ground level. Aerials	for	sales	would	provide an	overview	of the	house	and	grounds.		In	all	cases	UAV	coverage	would	be	more	cost	effective. Aerials	would	provide	p otential	clients	a better picture	of	the building	and	grounds. Because	of	it’s	smaller	size	and	operating	in	a	restricted	area, our	UAV	will	give business	a	safer	tool	for aerials	of	buildings	and	land
. A standard	fixed	wing or helicopter flying over	the	same	area would	be	more	costly,	nosier	and	dangerous
. Based	on	all	above	MCS	Communications	request	an	exemption	under	Section	333 p NOTE: The	accompanying	manuals	marked	‘C onfidential ’ contain proprietary information that	ha s	not	and	will	not	share	with	the	public	and	are	protected	from	release	under Freedom	of	Information	Act	5	USC	552	et.sc Check	List	and	Training	Syllabus	may	be	modified	slightly	as	safety conditions warrant	better methods of	providing	safety	and	training
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MCS	Communications - FAR	333	Exemption	Request