Dear Sir or Madam,

The purpose ofthis letter is to request an exemption to the various regulations which cannot rbe complied with during the operation of UAS equipment in the NAS, and to describe the manner and operational limitations which will meet or exceed the safety standards that are produced by the regulations. This petition is filed on behalf ofThurman S Dunn II, an ATP certificated pilot with 5,700

-hours oftotal time, and type ratings in the EMB

-145, EMB

-120, and BE

-1900. Mr. Dunn has extensive experience in the operation of UAS vehicles, including computer based UAS simulator experience involving abnormal/emergency operations related to UAS or Flight Controller malfunctions. Furthermore, Mr. Dunn has over a decade of experience in the airline/aircrew environment, which should facilitate the development of professional training standards and crew coordination forwhich safety offlight requires. The purpose ofthese exemptions will be to facilitate aerial photography and videography

. It is the desire of Mr. Dunn to apply forthe blanket COA that allows operations forflights: at or below 200' AGL; less than 55 lbs gross takeoffweight; during day VFR conditions; within visual line of sight; and at least:
5 nautical miles (NM) from an airpor t having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operational tower; or 2 NM from a heliport with a published instrument flight procedure.

OPERATIONAL LIMITATIONS AND EXEMPTIONS
The following describes the equipment to be used in operations, and the limitations which will provide an equivalent level of safety as that provided by current regulatory standards. A) UAS type and accessory equipment The UAS system to be utilized will be a DJI Phantom 2 Vision+. This particular platform has already received numerous exemptions based upon its small size, stable handling characteristics, limited kinetic energy potential, and the fact that it does not carryflammable liquids for propulsion. In addition to the UAS, the payload will consist of a small HD camera, a stabilizing Gimbal, and telemetry/video streaming hardware. The UAS utilizes an FCC compliant 2.4 GHz controllerforflight control, while the video link hardware utilizes an FCC approved 5.8 GHz transmitter. B) PIC and VO PIC duties may be performed by any individual whom holds either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in the applicable regulations. The PIC will be responsible for assuring that the visual observer (VO) is properly briefed and capable to perform theirfunctions at all times during the flight. The VO will comply with all medical/vision requirements as specified by a current FAA airman medical certificate or a validU.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a

possession, or the Federal government. C) Training and logbook hours for qualification
Initial training and logbook hours required for operation under this exemption will be waived for ATP pilot Thurman S. Dunn II, due to his overall experience in flight operations and extended history of remote piloting of small helicopter UAS and simulator training in such UAS vehicles (including the DJI Phantom 2). Mr. Dunn reserves the right to develop training standards consistent with traditional flight training programs (while modified in order to address the unique challenges of unmanned flight) in order to qualify properly certificated pilots to perform PIC duties under this exemption. Mr. Dunn will develop and maintain a training syllabus (including required hours) forthe purpose of pilot UAS training, and will make those documents available for FAA or DOT inspection. D) UAS limitations on operation The UAS will be operated in compliance with the visibility and cloud clearance requirements applicable to VFR flight in the particular airspace in which the operation will take place, except that under no circumstances will the UA be operated at less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. The airspeed limitation ofthe UAS will be a maximum of 87

-knots (100

-mph) groundspeed. A minimum battery reserve of 5

-minutes is required forflight planning or to continue flight once initiated, and any aural or visual low battery warning issued by the UAS controllerwill result in the termination ofthe mission and an immediate, safe landing. Any malfunctions or abnormal operation ofthe UAS system or controllerwill result in the termination ofthe flight and prohibit future operation until the causes ofthe malfunction or abnormal operation can be ascertained and corrected. Under all circumstances, logbook entries will be entered and maintained for the specific UAS in relationship to abnormal operations, malfunctions, or preventative maintenance, and those logbooks will be made available to FAA and DOT representatives. E) Preflight safety risk assessment As a part ofthe continuing development of safe operating practices, Thurman Dunn will develop a preflight safety risk assessment checklist that will include all manufacturer recommendations in full, and that will remain flexible to add additional items as operational experience dictates. Included in this will be the requirement to establish controllable boundaries which will allow flight to remain clear of non-participating individuals and property by a reasonably safe distance, and the establishment of safe landing sites in the event of an abnormality, or loss of remote control communication with the UAS. CFR EXEMPTIONS: Exemptions to regulations pertaining to airworthiness certification and aircraft noise standards are applied for under established Section 333 provisions.
14 CFR Part 61.23 (a) and (c). This part sets forth the requirements for medical certification which is addressed in Operations Limitations and Exemptions (Section B) above. The exemption is required due to the lack of specific guidance in the FAR for UAS operators, whileSection B ofthe petitioners accompanying Operations Limitations provides for an equivalent

medical standard to this part.
14 CFR Part 61.101 (e)(4) and (e)(5); Part 61.113 (a). These parts set forth the limitations with regards to flight for compensation or hire or in furtherance of a business. The petitioner requests relieffrom this part due to the fact that the UAS poses an extremely limited hazard to persons or property. The equivalent margin ofsafety is provided by the Operational Limitations and Exemptions above, in combination with the small mass ofthe aerial platform.
14 CFR Part 61.315(a). This part limits the aircraft that a sport pilot may operate. We request an exemption in order to allow a sport pilot to operate a UAS in conjunction with the established section 333 exemptions.
14 CFR 91.7(a) Under FAR 91.7, no person may operate an aircraft unless it is in an airworthy condition. As "airworthy" may be defined as the requirement to obtain an airworthiness certificate, the petitionerwould request an exemption from this FAR due to the inability ofthe current airworthiness process to provide a realistic path for airworthiness certification of small UAS aircraft. The limitations on UAS operation described herein, combined with the inherent increase in safety that is produced by replacing large aircraft operations with a small UAS, will produce an equivalent degree of safety.
14 CFR 91.119. FAR 91.119 sets forth the minimum safe altitudes over various areas. The petitioner requests an exemption from this part in order to accomplish the intended function of the mission forwhich he seeks an exemption. Given the extraordinarily small mass ofthe proposed vehicle, an equivalent level of safety can be obtained with much smaller clearances.
14 CFR 91.121. FAR 91.121 mandates various altimeter settings in order to maintain level flight. Petitioner requests and exemption from this FAR as the Subject UAV will not have the traditional altimeter required by this part. Operations with the Subject UAVwill, however, maintain an altitude at or below 200' AGL.
14 CFR 91.151 (a)(1) Petitioner requests an exemption from the fuel carrying requirements due to the rapid ability of UAS to land under normal operation. Equivalent safety margins are obtained by adherence to the greater of manufacturers reserve electrical load, or 5

-minutes of battery power remaining. 91.405 (a) Petitioner requests relief in conjunction with the airworthiness certificate release specified in section 333. 91.407(a)(1) Petitioner requests relieffrom this part due to the simplified maintenance functions that are required for a small UAS. Equivalent safety margins will be met by adhering to common practices and manufacturer recommendations with regards to maintenance functions. 91.409(a)(1) and (2) Petitioner requests relieffrom this part due to the lack ofguidance regarding proper annual inspection for a UAS, and on the same basis as the requested exemption to 91.407(a)(1). 91.417 (a) and (b) The requirement to maintain records kept under sections 91.417(a) and (b) relate to the exemptions requested for 91.407(a)(1) and 91.409(a)(1) and (2). The equivalent safety margins have been specified in the exemption request forthose parts.VALUE ADDED BY APPLICANT

In addition to the procedures and limitations that the petitioner agrees to abide by (which will result in an equivalent level of safety to the NAS), the extensive experience in professional flying with which the applicant possesses will allow the petitioner to contribute meaningfully to regulatory and training standards that can be implemented going forward in order to ensure safe operations ofsUAS vehicles.
Mr. Dunn looks forward to a continuing dialog and constructive interaction with regulators in the future, forthe purpose of assisting in the development of appropriate, professional standards to assist future generations in the proper operation of said aerial platforms in the airspace system. Please feel free to contact us with regards to any questions or comments that you may have with regard to this application. Thurman S. Dunn, Unmanned Air Services tdunns@hotmail.com 310

-847

-9844