Chris Turner 07/16/2015

323

- 839

- 9828 13921 W Saratoga Ave Morrison, CO 80465 bonemanchris@hotmail.com

Federal Aviation Administration:

Dear Sir or Madam,

I, Chris Turner , am writing pursuant to the FAA Modernization and Reform A ct of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Chris Turner , an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Chris Turner , may operate a s mall ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”) in accordance with FAA UAS Regulations &

Policies.

I would like to formally submit for an exemption from the follow ing Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91. 407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). To operate DJI’s following

UAS: Phantom 3, and Inspire 1 along the guidelines of the accompanying DJI Inspire 1, and DJI Phantom 3 Operator’s manuals. These UAS will be equipped with d etachable cameras and will be transported in proper storage.

This proposed exemption would allow me operation of unmanned aircraft systems (UAS) for the purpose of aerial videography/ photography as a service to the public/ business

interests. As found i n exemption No. 11138 (Trudeau), the FAA recently approved

similar use of a DJI UAS. These devices were selected because they have proven reliable flying capabilities managed by gyro stabilized flight, ground detection (phantom 3 and inspire 1) ,GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning home and prop guards.

This will act to further safety protocols exclusive to lightweight UAS’s specific to video and photography usage as I, Chris Turner , record flight data and other info rmation gained through permitted flight operations to share with the FAA through any required FAA reports to assists with future protocol and safety regulations. Specific section or sections

of 14 CFR which I seek relief and the reason I seek relief: 14 C. F.R. Part 21: Airworthiness Certificates Given the size and limited operating area associated with the aircrafts to be utilized by I, Chris Turner , an exemption from Part 21 meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the reform

Act.In all cases, an analysis of these criteria demonstrates that the UA operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than convention al aircraft operating with an airworthiness certificate without restrictions and conditions proposed. 14 C.F.R. 45.23: Display of marks: general The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or

tail on which to mark certain words o r phrases. Further, the two inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. 14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command The FAA has pre viously declared that additional manned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemptions to this regulation through Exemption Nos. 11062 and 11138. 14 C.F.R 91.7: Civil aircraft airworthiness Currently, since there is no certificate applicable to the UAs in question, this regulation is inapplicable. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the operator. 14 C.F.R. 91.119(c): Minimum safe altitudes I, Chris Turner will ensure that UAS do not operate any higher than 400 feet at ground level. I will not fly over congested areas. I will plan operations before hand, for proper flight safety, and proper height analysis as to avoid collisions. 14 C.F.R. 91.121: Altimeter settings The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety will be achieved by using this. 14 C.F.R. 91.151(a)(1): Fuel Requirements for fli ght in VFR conditions The UAS that I will fly are powered by electricity, using lithium polymer batteries that currently have a flight limit of approximately no more than 20 minutes. Therefore, due to the limitations of the batteries, it is currently impos sible to comply with part 91.151. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS.

I, Chris Turner , however will always fly safely whil e having the manuals of the DJI Phantom 2, DJI Inspire 1, and the DJI Phantom 3. 14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and ( 2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. However I,

Chris Turner , will perform preflight inspectio ns of the UAS before each flight as outlined in the operating documents. I, Chris Turner , will also follow manufacturer recommendations from said operating documents. Public Interest Aerial photography and videography as an available service to the public allows for a cheaper method to capturing imagery than its alternative. The alternative s are aircraft and helicopters. They are expensive, create lots of noise, and are much more threatening due to size and combustible fuel. I, Chris Turner , would gladly o ffer my services upon request and with proper coordination to any official search and rescue or emergency services organization to benefit the public. Also as mentioned in the Trudeau exemption, exemption No.11138: ““Manned aircraft conducting aerial filmi ng and photography can weigh 5,000 lbs. ormore, are operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons or more of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The pilot and crew will be remotely located f rom the aircraft. The limited weight reduces the potential for harm to persons or damage to property in the event of an incident or accident. The risk of an onboard pilot and crew during an incident or accident is eliminated with the use of a [sUAS] for th e proposed operation.”

I, Chris Turner , am seeking exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1 ), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b) With the exemptions of the mentioned rules I, Chris Turner , will be seeking to make my drone photography/videography se rvices available to the public.

Alternatively the public had looked to use helicopters and aircraft to achieve what I can offer in a safer, more cost efficient manner. By not using combustible fuel, flying at safe heights and strictly following the usage r ecommendations from DJI. These include but

are not limited to: ● Flying the following UAS Safely ○ DJI Inspire 1 ○ DJI Phantom 3 ● Flying below 400 feet ● Proper visual inspection of UAS before flights ● Keeping mentioned UAS in visual sight at all times w hen in operation ● Using an observer to

assist if needed ● Remain well clear of and do not interfere with manned aircraft operations, and avoid other aircraft and obstacles at all times ● Not intentionally fly over unprotected persons or moving vehicles ● Contact the airport or control tower before flying within 5 miles of an airport ● Not flying in adverse weather conditions such as high winds or reduced visibility ● Not flying under the influence of alcohol or drugs ● Ensure the operating environment is s afe ● Not flying over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, etc. ● Check and follow all local laws and ordinances before flying over private property ● Do

not conduct surveillance or photograph persons in areas where there is an expectation of privacy without the individual's permission.

Thank you for your time,

Chris Turner

323

- 839

- 9828 13921 W Saratoga Ave Morrison, CO 80465 bonemanchris@hotmail.com