1 October 27 , 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12
- 140 1200 New Jersey Avenue, S.E. Washington, DC 20590


### Petition	for **Section	333 Exemption	Under	14	CFR	§	11.81**  **to	Allow	Commercial	Use	of Unmanned	Aircraft	Systems**  **.** Petitioner: Christopher J. Riley

3684 Gould Drive Carmel, IN 46033 Rilo1982@gmail.com ( 317) 531
- 6022 Dear Sir or Madam, This application is substantially based on the FAA’s fi ndings in Exemption No. 11062 granted to Astraeus Aerial (Federal Aviation Admission (FAA)
- 2014 - 0352), Exemption No. 11109 Clayco, Inc. (FAA
- 2014 - 0507), Exemption No. 11208, Sky
- Futures UAS, Inc. (FAA
- 2014 -0641), Exemption No. 11252, Nixon Engineering Solu tions, LLC. (FAA
- 2014 -0763), Exemption No. 11306, Hawk Aerial, LLC. (FAA
- 2014 - 1023), Exemption No. 11380, First Team Real Estate, (FAA
- 2015 -0052), and in reliance on the analysis provided therein. 1. Sections from which exemptions are sought : Application i s hereby made for exemption from: a. FAA Modernization and Reform Act of 2012, PL 112
- 95 FEB. 14, 2012, Section 333 b. 14 CFR Part 21, subpart H c. 14 CFR Part 61.113(a) and (b) d. 14 CFT Part 91: i. 91.103(b)(2) ii. 91.105 iii. 91.109 iv. 91.119 v. 91.121 vi. 91.151 vii. 91.405 viii. 91.407 ix. 91.4092 x. 91.417 xi. 91.119 2. Relief sought: a. Christopher J. Riley wishes to operate small Unmanned Aircraft Systems (UAS) for commercial purposes to include (but not limited to) aerial surveying, mapping, infrastructure inspection, videography, photography, aerial data collection, news gathering, construction, archaeology, training/education, closed
- set film and movie production, emergency response/ public safety, cinematography, s earch/rescue, maritime/ port security, events, transportation support, and analyses. This relief is sought because commercial use of UAS is currently prohibited by law unless performed under an exemption. b. This exemption will cover use of the following a irframes, all of which will weigh less than 55 pounds including payload and energy sources: DJI Inspire 1 . DJI Phantom 1, 2 & 3. 3DR Iris+ . 3DR Solo. Other models to be added by future amendment to this exemption.
3. Public benefit: a. Use of UAS technolo gy to obtain imagery, information and data currently obtained by use of manned flight or manual methods: i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., power line inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging failures during stack or bridge inspections). ii. Reduces the cost of obtaining such information, which benefits consumers and the economy. iii. Reduces environmental impact by eliminating sources of hydrocarbon em issions from manned aircraft. 4. Safety not adversely affected: a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C. b. Aircraft will comply with maintenance and inspection requirements of the ma nufacturer. All repair and maintenance work will be conducted or approved by qualified personnel such as those authorized by Robotic Skies (or equivalent), and will require a test flight after such work. Records of all maintenance and repair work will3

be k ept in a mainten ance log for each aircraft, and available upon request. c. All flight operations will be conducted by two individuals who will maintain verbal communication capability with each other at all times during the flight, and who will remain sta tionary on the ground during the flight operations: d . A Pilot In Command (PIC) who possess the following credentials: 1. An airline transport, commercial, private, recreational, or sport pilot certificate. 2. A Third Class medical certificate issued under 14 CFR 67 or valid U.S. driver license. 3. A Bi
- annual flight review under 14 CFR 61.56 4 . At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft (or UAS fixed
- wing in the case of fixed
- wing flight operations under this exemption). Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119. 5 . At least 5 hours of flight experience and 3 takeoffs and landings in make and model being flown in t he prior 90 days. Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119. e. A Visual Observer (VO). f . All flight operations will be conducted in accordance with valid Certificates of Authorization. g . All flight operations will comply with the following: i. The manufacturers’ Aircraft Flight Manuals and operation guidelines. ii. flight operations policies including lost communication and other emergency an d safety procedures. iii. Conducted in visual meteorological conditions ( VMC ) conditions during daylight hours. iv. Pilot in Charge ( PIC ) and Visual Observer ( VO ) will maintain visual line of sight (VLOS) at all times. v. Pre -flight inspections (including ground control station, if any) and safety risk assessments will be conducted prior to each flight. vi. Flight altitudes will remain at or below 400 feet above ground level. vii. Flight speeds will not exceed 87 knots. viii. Not take place over urban areas or within 5 miles of an airport. ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on the ground without their prior permission. x. Each flight will be logged in both the PIC’s logbook and the aircraft logbook. xi. Not exceed 80% of the battery capacity of the aircraft. xii. Any incidents will be reported within 24 hours of occurrence. xiii. Any applicable local Flight Standards District Office ( FSDO ) requirements. xiv. All other applicable regulations concerned with the operat ion of aircraft. 91.119 Minimum safe altitudes: 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 witho ut undue hazard to persons or property on the surface.4

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radi us 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 sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vesse l, vehicle, or structure. (d) Helicopters, powered parachutes, and weight
-shift
- control aircraft. If the operation is conducted without hazard to persons or property on the surface — (1) A helicopter may be operated at less than the minimums prescribed in p aragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA. Please advise us of any additional information or changes that are required. Sincerely, Christopher J. Riley October 27 , 2015