September 27, 2015

Potomac Aerials Steven Monell 9703 Thornville Drive Fort W ashington, MD 20744 Cell (703) 981

- 9547 Fax (240) 390

- 2386 Email paerials60@ yahoo.com US Department of T

ransportation Docket Managem ent Sy stem 1200 New Jersey

Av e. SE Wa shington DC 20590 RE: Exemption Request Section 333 the F AA Reform Act of 2012 Attachments: 1) Copy of Private Pilot Certificate and current Third Class Medical Certificate 2) DJ I Phantom 3 Pro Specifications Refere nces: 1) F AA Exemption No. 1 11 38, Regulatory Docket No. F

AA

- 2014

- 0418 in the matter of the petition of DOUGLAS TRUDEAU 2) F AA Exemption No. 1 11 36, Regulatory Docket No. F

AA

- 2014

- 0S08 in the matter of the petition of ADV

ANCED AV IA

TI ON SOLUTIONS, LLC 3) F AA Exemption No. 1 1080 Regulatory Docket No. F

AA

- 2014

- 03SS in the matter of the petition of FL

YI NG CAM I

NC Dear Sir or Madam, In accordance with the F

AA's Guidelines for Submitting Petition for Exemption under Section 333 of the FA A Modernization and Ref orm act of 2012, I Steven Monell, owner and operator of Potomac Aerials referred to hereafter as the petitioner, request exemption to the following sections of Ti tle 14, Code of Federal Regulations:
61.1 13(a); 61.1 13(b); 91.1 19(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) In order to operate small unmanned aircraft s ys tems (UAS) commercially in airspace regulated b y t he Federal Av iation Administration (F AA) for the purposes of Aerial Photography , Cinematograph y

, Vi deograph y, I nspections, Surveying and other flight operations that could be performed safel y and more cost effectively with the use of small UAS at low altitude within the US National AirspaceSy stem as compared to a manned aircraft. Operations will on ly be performed at the request of and with the authorization and consent of clients and their authorized agents in order to facilitate commerce and raise awareness of beneficial uses of small UAS. So long as such operations are conducted within and under the conditions outlined herein or as may be established by

the F AA as required b y section 333. The conditions identified and proposed b y the petitioner are drawn from references 1

- 3. The F ARs The petitioner seeks the exemption from the above mentioned F AR s for the following reasons: 61.1 13(a) & (b): The petitioner requests relief in order to facilitate utilization of pilots who hold a PRIVAT E PILOT(or greater) certificate. An y pilots operating under this exemption would be required to comply

with an y c onditions as set forth and in a similar fashion as the previously granted exemptions.
91.1 19(c) As discussed in Exemption 1 11 39 (Douglas T rudeau), 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 of "congested areas" and "densel y populated." The petitioner reques ts waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods.91.121 As discussed in Exemption 1 11 38 (DOUGLAS TRUDEAU), this is inapplicable since the UAS does not have an altimeter and instead util izes GPS with a barometric sensor for altitude information. 91.151(a) As discussed in Exemption 1 11 36 (ADV ANCED AV IA

TI ON SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than prescribed minimums including Exemption NO.s 2689, 5745, and 10650. In addition similar UAS specific relief has been granted an Exemption No.s 881 1, 1080, and 10673 for day time, VFR operations. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. In formation provided in the operating documents discusses procedures regarding remaining battery power management. The documents contain a condition in which the PI C will initiate a landing procedure when the battery remaining re aches a specified level. Given the limitations on proposed operations and the location of those proposed operations, the F AA found that a reduced minimum power reserve for flight in day time VFR conditions was reasonable. 91.405(a); 91.407(a); 91.409(a) (1 ) & (2); 91.417(a) & (b) As discussed in Exemption 1 11 38 (DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure the UAS is in a condition for safe flight in accordance with the operating documents. The F AA found that adherence to the petitioners operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection and record keeping, were suf ficient to ensure that safety would not be adversely

af fected.**The UAS**

The DJ I Phantom 3 Professional is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to carry a high definition camera aloft. They have an advertised maximum speed of less than 30 kts (15 m/s) and a maximum climb rate of less than 1200 fpm (6 m/s), They are powered b y 4 electric motors with a distance between the motors of less than 14 inches (350 mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric s ensor to augmented with Global Positioning Sy stem (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (Re) unit. Real time video and telemetry information is transmitted back to a gro und control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from the PI C, camera imagery , and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Alt itude can be limited by the onboard flight controller and maximum altitude can be preprogrammed b y t he PI C. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry data and external ligh ting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when battery reaches a predetermined low state. It is anticipated that flights will usually

last less than 15 minutes. More information is ava ilable in attachment 2. **Risk Mitigation** The petitioner has reviewed F AA exemptions references 1

- 3 Conditions and L imitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate ris k and ensure public safety

. A preflight and post flight checklist will be developed and employ ed to ensure that UA airworthiness will be maintained for flight operations. Flight time and maintenance logs will be maintained to ensure tracking on failure pro ne components. The petitioner requests that in a manner similar to reference 2, he be allowed to operate within 5 miles of an airport provided that: "The UAS may

not operate in Class 8, Class D airspace without written approval of the F AA Th e UAS may not operate within five nautical miles of the geographic center of a non

- towered airport as denoted on or current F AA

- published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accor dance with a NOT AM as required b y the operator's GOA The letter of agreement with the airport management must be made available to the Administrator upon request. " Operations within 5 miles of an airport are not anticipated to be routine, but the petitio ner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption should the need arise. Operations within class B airspace are not requested due to the lack of a mode C transponder

. **Public Inter est**  Use of the UAS in lieu of a manned aircraft would enhance safety and reduce environmental impact compared to similar operations conducted with much larger fuel laden manned aircraft Additionally , the use of UAS to facilitate commerce can help to encourage economic growth. Operations for this petition will enable service for propert y owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be display edthrough ground level vid eograph y/ photograph y. Aerial photograph y is a valuable marketing tool that can facilitate increased commerce and enhance personal photograph y. Crop surveying and inspections could lead to decreased use of pesticides and fertilizer and conservation of wat er as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site ef ficiency , improve volumetric estimations and reduce risk. The petitioner will provide clients with the photographic data for these purposes i n a for hire basis acting as an independent contractor

. A visualobserver will be utilized. Flight data including UA flight time, Control unit operation time, incident,accident, and details concerning an y deviations from normal operations will be availabl e to the FA A for use in collecting data regarding the use of UAS as a part of this application. This data can be submitted to the F

AA via reports as required b y the F AA.
**Conclusion** The petitioner is requesting this exemption for the purposes of "aerial ph otography , cinematograph y, videography

, mapping, inspections and other flight operations." The reason for such a general and broad based request is that the petitioner wishes to utilize a strategy that allows maximum flexibility to utilize the UA

to its fu llest potential within the constraints of this request, without the long turnaround time associated with additional exemptions. The petitioner plans to offer services to individuals or companies seeking to enhance their business in a safe and lawful way

. The petitioner knows from applied experience since 2006 fly ing manned aircraft in and outside of the W

ashington DC FRZ and ADIZ that there is extensive demand for lawful aerial photograph y and videography

. The petitioner has 430 hours fly ing experience ( Private Pilot Single Engine Land), 362 hours as pilot in command.The petitioner holds a private pilot pilot certificate (single engine land) and a current third class medical certificate. The petitioner owns UAS, DJIPhantom 3 Professional which he has flown on various locations outside the W

ashington DC 15NM to develop flight and photograph y experience. He has executed many takeoffs and landings, and has demonstrated continuous proficiency . He has experience with the fail safe modes of the aircraft, having practiced emergency procedures as described in the DJ I operating manual. The petitioner plans to utilize the UA below 400' AGL, within visual line of sight (VLOS), within 500' laterall y of the PIC, and with a visual observer at all times.
Restpectu lly Steven Monell Potomac Aerials