### February 1, 2016 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washing ton, DC 20590 Re: Requestfor Exemption under Section 333 ofthe FAAModernization and Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations.
Name and Address of Petitioner: James Parrish 932 Colonial Drive StAugustine, FL 32086 561-929-6903 Born2flyone@yahoo.com
Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, James Parrish, the Petitioner, request exemption from the following Federal Aviation Regulations in orderto legally operate an Unmanned Aircraft System (UAS) in the National Airspace System. Regulations from which the exemption is requested: 14CFR 21 H 14 CFR 45.23 (b) 14 CFR 61.113 (A) 7 (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b)(2) 14 CFR 91.103 (b) 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14CFR91.151 (a) 14 CFR 91.203 (a) & 

### (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) 

### &(b) 14 CFR 91.417 (a) & (b) 14 CFR Title 14 Chapter 1Sub D Part 60 thru 67- 61.1 to 61.429 The Petitionerwishes to be granted the exemption for use ofthe UAS of commercial operations list below. to operate the DJIInspire 1 UAS for commercial purposes ofaerial videography and photography as a service to public and business interests, including: real-estate photography and videography, wedding and private individual photography and videography, public and commercial photography and videography, and agricultural photography and videography. Requestfor Exemption, Section 333 ofthe FAA Reform Act pertaining to Federal Aviation Regulations: The Petitioner requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of UAS's.


### 14 CFR 21 H: Airworthiness Certificates**~r**



### ¥ Certification Proceduresfor Products and Parts Reason for Exception
It has been determined that similar UAS's do not require an airworthiness certificate as granted in Exemption No. 11623, 11650, 11664 and 11734.


### 14 CFR 45.23 (b): Marking ofthe Aircraft
Because the DJI Inspire 1 does not have a cabin, cockpit, pilotstation, fuselage, boom, ortail on which to mark largewords, numbers, or phrases, I request exemption from the above regulation. However, in efforts to complywith the above regulation Iwill affix a small label to the external hull ofthe UAS with the FAA registered N number
The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.


### 14 CFR61.113 (a), (b): Private Pilot Privileges and Limitations
The regulation provides that no person may serve as a required pilotflight crewmemberofa civil aircraft ofthe United States, unless that person: (1) has a pilot certificate or special purpose authorization issued underthis part in that person's physical possession or readily accessible. (2) The flight is only incidental to that business or employment. (3) The aircraft does not carry passengers or property for compensation or hire.
Reason for Exception
The Petitionerwill follow all manufacturers' training program and safety manual. I also believe these requirements are unnecessary for pilot controlled droneflight. Additionally, current FAAproposals have omitted this as a future requirementfor small UAS's.


### 14 CFR91.7 (a): Civil AircraftAirworthiness Civil AircraftAirworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy condition.
Reason for Exception It has been determined that similar UAS's do not require an airworthiness certificate, howeverthe petitionerwill ensure airworthiness through the combined use ofthe manufacture's Operations Manual and preflight checks.


### 14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft
This regulation providesthat no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure thatflight manual information is available to the aircrewwhile operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation; the documentation would not be available to the crew.
Reason for Exception The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control pointwhere the pilotflying the UASwill have immediate access to it. The FSS has issued the following exemptions to this regulation: Exemption #8607, 8737, 8738, 9299, 9299Ato list a few.


### 14 CFR 91.103 (b): PreflightAction: \'*L This regulation requires each pilot in commend to take certain actions before flight to insure the safety offlight. AS FAAapproved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. The petitionerwill take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight.
14 CFR 91.109: Flight Instruction
The regulation provides that "No person may operate a civil aircraftthat is being used forflight instruction unless thataircraft has fully functioning dual controls."
Reason for Exception UAS's and remotely piloted aircraft, by their design so not havefully functional dual controls. Flight control is accomplished through the use ofa control box that communicateswith the aircraft via radio communications. The FAA hasapproved exemptions forflight training withoutfully functional dual controls for a numberofaircraftand for flight instruction in experimental aircraft. See exemption Nos. 5778K & 9862A. The equivalent level ofsafety provided by the fact that neithera pilot nor passenger will be carried in the aircraft and bythe size and speed ofthe aircraft.
14 CFR 91.119: Minimum SafeAltitudes
The regulation provides that over sparsely populated areas the aircraft cannot be operated closerthan 500 feet to any person, vessel, vehicle, or structure. Since the aircraftwill be operating at a maximum of 400 feetAGL, we cannot complywith this requirement.
Reason for Exception
The use of UAS will be flown no higherthan 400 feet AGL in LOS over developed and developing residential areas that may be considered congested areas. Thatwill not always be the case when providing a 'Property Survey' flight because they could be conducted overempty lots oracreages with no structures. In the case offlying overor nearexisting private propertywhile providing aerial imagery, property inspections, and property assessments, landownerswill be notified in person by the Petitioner, or by a card left behind by the Petitioner if requested. The Petitionerwill review with the landowners of associated risks to people and property. Due to the small size ofthe UAS the associated risk to persons, vessels, vehicles and structures is notcomparable to manned aircraft and should betaken into consideration.
14 CFR 91.121: Altimeter Settings
This section requires that each person operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating below 18,000feet MSL.
Reason for Exception
Most UAS do not have a barometricaltimeter. Ifdoes have a GPS thatwill calculate altitude. The Petitionerwill limitflights to a maximum altitude of400feet AGL as granted in Exemption No. 11623, 11664, and 11734.
14 CFR90.151 (a): Fuel Requirements for Flight in VFR Conditions
Fuel requirements forflight in VFR conditions: (a) No person may begin a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed. (1) During the day, to fly afterthat for at least 30 minutes.**-~~eason** 

### for Exception The UAS provides a low battery warning to indicate when you should return the UAS to the launch point. In addition, a "low" and "critical" battery level warnings and implemented a "return to Home" (or "Go land") action in these situations. The Petitionerwill not initiate a flight unless (considering wind and forecastweather conditions) there is enough power to fly at normal cruising speed to the intended landing point and all flights will be conducted during daylight hours and attimes not to be a nuisance to others.
14 CFR 91.203 

### (a) & (b): Carrying Civil Aircraft Certification and Registration
This regulation provides as follows: • No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate. • No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under 19.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew.
Reason for Exception To obtain an equivalent level ofsafety and meetthe intentof91.203, documentation will be housed at a ground control pointwhere the pilot is flying the UAS for immediate access to the extentthey are applicable to the UAS's. In doing some research the FAA has issued numerous exemptions to this regulation.
14 CFR 91.405 

### (a): Maintenance Inspections
Each owner oroperator ofan 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) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter.
Reason for Exception
The Petitioner shall inspectthe aircraft priorto everyflight. The Petitioner alsowill follow the manufacturer's recommended preflight checklistand make any repair necessary before flights occur. The Petitionerwill also maintain a log ofany maintenance or repairs performed.
14 CFR 91.407 

### {a) {1): Maintenance Operation after maintenance, preventative maintenance, rebuilding oralteration: (a) No person may operate any aircraftthat has under gone maintenance, preventative maintenance, rebuilding, or alteration unless (1) it has been approved for return to service by a person authorized under43.7 ofthis chapter.
Reason for Exception The Petitionerwho has the responsibility for the operation and safety ofthe UAS will follow the manufactures suggested replacement parts.
14 FR 91.409 (a){l) 

### & (2): Inspections Inspections: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) an annual inspection in accordancewith part 43 ofthis chapter and has been approved for return to service by a person authorized by 43.7 of this chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. No inspection performed under paragraph (b) ofthis section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an "annual" inspection in the required maintenance records.
Reason for Exception The Petitionerwill follow manufacturer's suggestions to ensure thatthe UAS is in a condition for safe flight at all times.

## v14CFR91.417 (a) 

### &(b): Maintenance Records Exceptforwork performed in accordance with 91.411 and 91.413 each registered owneroroperator shall keep the following records (l)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v)(vi) for the periods specified in paragraph (b) ofthis section: ( 1) (2) (3)
Reason for Exception The Petitionerwill keep a record ofall repairs and modifications. The Petitioneralso proclaims to use approved manufactured parts for all repairs and modifications.
14CFRTitle 14 Chapter 1 Subchapter

### 0 Parts 60thru 67-61.1 to 61.429: Pilot Certification This section pertains to flight rules, pilot certificate requirements, manuals, etc.
Reason for Exception The Petitioner believes thatthese requirements are unnecessary for pilot controlled drone flights and current FSS proposals have omitted this as a future requirement for small UAS's. All PIC'swill hold an airline transport, commercial, private, recreational, or sport pilot certificate, aswell as an FAAairman medical certificate or a valid U.S. driver's license. Summary With the exemptions ofthe mentioned rules I, James Parrish, will be seeking to make my UAS photography/videography services availableto public and commercial interests. The FAA has authorized similar operations under Exemption Nos. 12045and 12053. Alternatively, publicand commercial interests had previously sought the use ofmanned aircraftto achieve what I can offer in a safer, more cost-efficient and environmentally-friendly manner by not using combustible fuel, flying atsafe heights and strictlyfollowing the usage recommendations from DJI These include butare not limited to:

• Flying the DJI Inspire 1 safely in accordance with its operator's manual •Alwaysflying below400feet • Completing thorough inspection of UAS before and afterflights • Keeping the UAS in visual sight atall timeswhen in operation • Using an observerto assist ifneeded • Remaining safely clear ofand do not interferewith manned aircraft operations • Notflying directly over unprotected persons or moving vehicles • Notflying within 5 miles ofan airport orcontrol tower • Notflying in adverseweather conditions such as high winds, rain, or impaired visibility • Notflying underthe influence ofalcohol ordrugs • Ensuring the operating environment is safe • Notflying oversensitive infrastructure or property such as power stations, water treatmentfacilities, correctional facilities, etc. • Checking andfollowing all local laws and ordinances beforeflying over private property • Not conducting surveillance orphotographing persons in areaswhere there is an expectation ofprivacywithoutthe individual's permission
In Conclusion: I, James Parrish, the Petitioner requestfor exemption from the above mentioned Federal Aviation Regulations in orderto legally operate an Unmanned Aircraft System (UAS) in the National Airspace System in orderto perform the Operations outlined above and work in a safe and controlled environment. The Petitioner hopes for a timely consideration as I have made a considerable investment in time and finances on this project. Sincerely,

James Parish