## DUAV 1704 Edgewood Drive Milford IA. 51351 712.330.6417 Petitti@ duav.org



### DUAV Okoboji Iowa 712.330.6417 Petitti@duav.org 

### March 23rd , 2015



## Request for exem

ption under FAA Modernization & R eform Act of 2012, Section 333, to operate an Unmanned Aerial System for Aerial Photography and Aerial Inspections.

**Petitioner’s information** Thomas Pe t itti 1704 Edgewood Drive Milford, IA 51351 712.330.6417 Petitti@duav.org DUAV LLC, 

### U.S. Department of Transportation Docket Manage me nt System 1200 New Jersey Ave , SE Washington, DC 20590

**Petition for Exemption of CFR 14:** 45.23(a)&(b);61.113(a),(b),&(2); 91.7(a)&(b); 91.119(a),(b),&(c); 91.151(a),(1),&(b); 91.405(a); 91.407(a)&(1); 91.409(a),(1),&(2); 91.417(a)&(b)

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org Dear Sir or Madam, Request for relief from an airworthiness certification requirements under the FAA Modernization and Reform Act of 2012, Public Law 112

- 95 FEB. 14, 2012, Section 333.


## Section 14 CFR **§45.23 Display of marks; general.**  (a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed b y the registration number of the aircraft. Each suffix letter used in the marks displayed must a lso be a Roman capital letter. (b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable. The UAS aircraft , will be permanentl y marked in multiple places with contact information containing P.I.C & owner’s Name, Address, & Phone Number. In compliances with 14 CFR Section 45.29 (f) , the UAS will also be marked with “Experimental ” in as large as practical size of print on at least two surfaces.



## Section 14 CFR **§61.113 Private pilot privileges and**  **limitations: Pilot in command.** (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or propert y for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may , for compensation or hire, act as p ilot in command of an aircraft in connection with an y business or emplo ym ent if: (2) The aircraft does not carry passengers or property

for compensation or hire. Although no souls will be aboard , the UAS operations will be planned with the same level of safety as a commercial operation, u nder the command of a private pilot , holding an up to date medical certificate and photo I.D. A ll operations will follow a Standard weather Briefing, a preflig ht check, a nd a run up. All flights will follow a predetermined route , and maneuvers within clear airspace. The level of risk associated with the operation of the UAS are so diminished form

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org the level of risk associated with commercial operations contemplated by part 61 when drafted, that allowing operations of the UAS as requested with a private pilot as the operator exceeds the present level of safety achieved by 14 CFR Section 61.113 (a) &(b).


## Section 14 CFR **§91.7 Civil aircraft airworthiness.**  (a) No person may

o perate a civil aircraft unless it is in an airworthy condition. (b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworth y mechanical, electrical, or structural conditions occur. As there is no Airworthiness certificate issued for this aircraft, should this exemption be granted, no FAA regulatory

standard will exist for determining the airworthiness. Given the size of the aircraft and the requirements contained in the manual of maintenance , and use of safety checklists prior to each flight as set forth in Section B , and Section G, an equivalent level of safet y will be provided.



## Section 14 CFR **§91.119 Minimum safe a**  **ltitudes: General.** Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property o n the surface. (b) Over congested areas. Over an y congested area of a cit y, town, or settlement, or over an y open air assembl y of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure The equivalent level of safet y will be achieved given the size, weight, and speed of the UAS as well as the location of operated. No flight will be taken without the permission of the propert y owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, attempts will be made to contact all affected individuals rega rding the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. UAV limit Proposed herein, and the lack of flammable fuel, an y

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org risk associated with these operations is far less than those presentl y presented with conventional aircraft. In addition, the low

- altitude operations of the UAV will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.


## Section 14 CFR **§ 91.121**  **Altimeter settings.** (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may

be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MS L, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a) (1) (i ) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before depar ture; or (2) At or above 18,000 feet MSL , to 29.92 ′′ Hg. (c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the approp riate number of feet specified below, according to the current reported altimeter setting: The UAS does not operate by use of Barometric Altimeter but instead a digital GPS altitude read out for AGL. An equivalent level of safet y will be achieved b y the op erator, pursuant to the Manual and Safety

Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.



## Section 14 CFR **§91.151 Fuel requirements for flight in**  **VFR conditions.** (a) No person may

begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

—

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org (1) During the day , to fly after that for at least 30 minutes; or (b) No person may

begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 20 minutes. The battery (s) powering the UAS varying time from 8 minutes to 12 minutes per battery . In 15 degree Celsius, low wind, VFR conditions flight will last approximately 12 minutes with all powered components functioning. Given th e l imitations on the UA S proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight VFR conditions is reasonable. An equivalent level of safety can be achieved by

limiting flights to have enough battery reserve to ensure the UAS lands at a safe ground station with at least 20% of battery power determining by onboard monitoring and by the pilot. A notice in a decline of power performance or the 20% reserve mark has been met enough time will be adequate to return the UAS to a safe landing station within the predetermining route.



## Section 14 CFR **§91.405 Maintenance required.**  Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter; Although this sections apply onl y to aircraft with an airworthiness certificate; ro ute and pre

flight inspections and maintenance will be accomplished by the P.I.C and owner. An equivalent level of safety

will be meet due to the lack of size and payload of the UAS, as well as operating in restricted areas for short limited periods of tim e in only VFR conditions will ensure extreme precaution and safet y.



## Section 14 CFR **§91.407 Operation after maintenance,**  **preventive maintenance, rebuilding, or alteration.** (a) No person may

operate any

aircraft that has undergone maintenance, preventiv e maintenance, rebuilding, or alteration unless

—

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org (1) It has been approved for return to service b y a person authorized under §43.7 of this chapter; All preventive maintenance will be performed b y a licensed privat e pilot and owner operator

. Although there are no engines, electric motor and amplifier component , replacement will be done with equivalent safety as an aircraft power plant . Camera equipment alterations will also be done with equal caution concerning balance, power, and weight . Any major airframe work, or electrical (circuit board, reprograming, or calibrating ) will be done b y professional UAS builders.



## Section 14 CFR **§91.409 Inspections.**  (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an air worthiness certificate in accordance with part 21 of this chapter. All Inspections will be performed in the pre

- flight check and run up check near initial take off for each battery . No commercial UAS operation will occur after any form of maintenance unles s a test flight in a sparsel y populated areas away from any person or propert y has been conducted involving every

maneuver and all electrical components.



## Section 14 CFR **§91.417 Maintenance records.**  (a) Except for work performed in accordance with §§91 .411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, pro gressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

—

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (IV ) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date . If the AD or safet y directive involves recurring action, the time and date when the next action is required. (VI ) Copies of the forms prescribed b y §43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors , propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work o r for 1 year after the work is performed. (2) The records specified in paragraph (a) (2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operat or under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. Equal level of safet y and records in accordance with CFR 14 Section 91.405. All records will be included in a maintenance record folder as well as a designated log book. Including date of maintenance started and finished, name of qualified person or compan y who performs the maintenance, and type of maintenance performed on UAS.

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org 

## Public Summa **ry** Pursuit to 14 CFR Part 11 the following summary is provided for the publication in the Federal Register, should it be determined that publication is needed. Applicant request an exemption from the following rules Code of Federal Regulations, Title 14, Cha pter 1; Volumes 1 & 2: 45.23(a) & (b); 61.113(a), (b), & (2) ; 91.7(a) & (b); 91.119(a), (b) & (c); 91.151(a), (1), & (b); 91.405(a); 91.407(a) , & (1); 91.409(a), (1), & (2); 91.417(a) & (b) Approval for exemptions allowing commercial operations of a UAS for aeri al photograph y and videograph y intended for inspection and video reproductions in the following industries: Real Estate, Advertising, Environmental Research along with Water Quality and Shoreline Research , and Inspection of Wind T urbines , B ridges , or other large industrial buildings. Over open and moving waters, dangerous or hazardous places, and unreachable places b y any other category of aircraft. Intended to Reduce heavy lead based pollutants in the air and reduce risk of injury to pilots and pa ssenger photographers. The limited size, weight, and distance of the UAS will also protect people and propert y on the ground. Compared to tradition forms of aerial photograph y involving large engine powered aircraft at low altitudes, over populated condens ed areas, making abrupt sharp maneuvers we’ve removed almost all negative aspects with this new and growing technology

th at we hope to promote and share with the public to build a positive image and make the airspace safer. In m y small and growing community in the northwest Iowa’s great lakes; we bring in millions of tourist each ye ar . In efforts to promote my community

with new safer technology then traditionally

done in the area. The UAS will be used to help nonprofit organ ization in the local area such as : Historic Arnolds Park Inc., Keep Okoboji Blue, and Iowa great lakes water safet y council. All these organizations will benefit from the future use of a UAS. Allowing closer steadier footage, but also reducing noise greatl y over natural wildlife refuges, parks, and forests that surround our lakes area. Reducing bird strike issues, and insuring other large wild life safet y. Efforts to promote real estate sale and grow the local year round community. I hope to help local busi ness advertise themselves with new footage that could never be achieved before.

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org 

## Privacy All commercial UAS operations will be conducted over private and controlled access propert y with propert y owner’s prior consent knowledge with respect to an y temporary flight restrictions

. Only those who have giving prior consent and have agreed to be photographed or filmed and to be involved in the area of operation may be near the P.I .C., subject of filming, and along predetermined route of UAS. Any person or owner of property (public or private) ask to have images removed will be allowed. All compliances will be meet by an y state or local privacy laws. 

## Accident & Indecent Reporting In the event of an accident or incident all insurance or damages will be covered b y DUAV LLC. The PI C of the UAS shall file a report on board form 6120.1/2 within 10 day s after an accident. A report of an incident for which immediate notification is required (830.5) shall be filed only when requested b y an auth orized representative of the board.



## Drug and Alcohol No person may

act as PIC or separate spotter/crewmember of UAS/aircraft while having a .04 percent b y weight or more alcohol in the blood or if any alcoholic beverages have been consumed within the pr eceding 8 hours. No person my act as crewmember of UAS if using any drug the affects the persons faculties in an y way contrary to safety . Any

operation or attempt to operation under either of these conditions is grounds for denial of application for a certificate, rating, or authorization issued under 14 CFR Part 91. 

## Conclusion Satisfaction of the criteria provided in section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas and operations within visual line of sight and national security - provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s UAS in photography and inspection industry

pursuant to the Manual appended hereto.

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org Thank you for your time and consideration. Sincerel y ,

Thomas J Petitti , Esq. PPL D UAV LLC,


## Flight Manual & Operating Procedures
**Flight Restrictions**

 No commercial operation will occur with a UAS gross weight exceeding 55 pounds.
 No UAS operation in any controlled airspace.
 All UAS operations will have a secondary spotter on location at all times.
 Complete logo book of flights time and safety track records
 All UAS flight operations will never exceed 400’ AGL and will never lose visual co ntact with the PI C.
 All commercial operations will take place over private propert y with prior consent from property owner.  All required permits and licenses will be obtained form the local count y and state of the commercial UAS operation.
 The UAS will no t operate over densel y populated areas.
 The UAS will not operate at airshows.
 The UAS will not operate over any open air assembly of people.
 The UAS will not operate within 5 nautical miles of an y airport without prior notice and radio communication.
 UAS o perations will be restricted to civil day light hours and VFR weather conditions.
 The PI C will brief anyone involved with or near the UAS operation on proposed route and maneuvers for each flight, along with an y possible risks in the operating area.

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org  No fli ght will be conducted without a full pre

- flight inspection by the PIC before each operation or change to weight and balance of the UAS.
 UAS operations will never be conducted for the purpose of hunting, trapping, or spotting.



## Pre
**- Flight Checklist** 

 Test each battery

with a voltmeter before powering UAS, and c heck batteries periodicall y in 5 minute intervals.
 Check all wiring for loss connections and an y issues.
 Check propellers for an y cracks or chips, assure leading edge of blades are smooth.
 Make sure a ll electric motors are clean and move freel y.  Assure all structural plastic appendages are strong and screwed full y. 

## UAS Start Up

 Power Devo7 transmitter and first person view sy stem and insure full battery power.
 Power an y addition gimbal and camera.
 Power DJ I F550
 Wait for DJIF500 to connect with GPS, and find its home point
 Recalibrate DJ I F500 compass if operating in a new location.


## UAS Run Up

 Check all flight controls make sure they are free and correct.
 Check all propellers with an optical tac hometer from equal power distribution.
 Throttle 50% insure UAS is properly balanced while in air.
 Check flight controls while hovering and make sure controls are correct.


## UAS Shut Down

 Idle controls and propellers
 Unplug UAS

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org  Turn off camera and gimbal
 T urn off first person viewing s ys tem
 Turn off Devo 7 Transmitter



## TO REGAIN CONTROL AFTER LOST RADIO

**CONTACT** 1. Failsafe = ON 2. Throttle = 50% 3. Mode = ATTI 4. Failsafe = OFF 5. Mode = GPS



## DeV **ention 7 Transmitter** If radio contact is not restored, the UA will automatically

continue at 60 ft

. above its last elevation before losing contact toward its takeoff point, then descend and land there autonomously

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org

### DUAV Okoboji, Iowa 712.330.6417 Petitti@duav.org 

## DJI F550 **Rotorcraft**

F5 50_ User_Man ua l_ v1. 9_ en .pdf Figure 1 DJI F550 Manual Click to Expand 

## Specifications **Frame Diagonal Wheelbase**  550 mm **Frame Weight** 478 g **Takeoff Weight** 1200g ~ 2400g **ESC Current**  30A OPTO **Signal Frequency** 30Hz ~ 450Hz **Battery** 3S ~ 4S LiPo **Motor Stator size**  22×12mm **KV** 920rpm/V **Propeller** 10 × 3.8in (@3S); (Optional 8 × 4.5in (@4S))