U.S. Department of Transportation

Docket Management System 1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12

- 140 Washington, DC 20590 

### RE: Petition for Exemption under **Section 333 of the FAA Modernization and Reform Act and Part 11.81 of the Federal Aviation Regulations** 
**Docket ID:__________________________**

September 4, 2015 **Petitioner:** Precision Aero

- Graphics & Imaging James F. Spicer 1119 East 2 nd . St. Sulphur, OK 730 86 TEL: (580) 277

- 0233 Email: lowlevlflyer@gmail.comDear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11.81, Precision Aero

- Graphics & Imaging hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") , to allow commercial operation of its small, unmanned aircraft for, but not limited to general photography and real estate applications, aerial inspection and survey, ag ricultural imaging and survey, and search and rescue . All operations shall be conducted within and under the conditions and limitations outlined previously by the FAA as required by Section 333 and conducted in compliance with the attached operator’s manu als. No commercial operations have been conducted thus far and will not be conducted until a petition is granted. 1. Sections from which exemptions are sought: Application is hereby made for exemption from: a. 14 CFR Part 21, subpart H b. 14 CFR Part 61.11 3(a) and (b) c. 14 CFR Part 91: i. 91.103 ii. 91.105 iii. 91.109(a) iv. 91.119 v. 91.121 vi. 91.151 vii. 91.203 (a) & (b) viii. 91.405 ix. 91.407 x. 91.409 xi. 91.4172. Relief sought:

a. Ghost Drone Imaging wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but not be limited to) general photography and real estate. This relief is sought because commercial use of sUAS is currently prohibited by law unless performed under an exemption. b. This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds including payload and energy sources: i. DJI Inspire 1 (See http://www.dji.com/product/inspire

- 1 ) i i. Other models to be added by future amendment to this exemption. 3. Publ ic benefit: a. Use of UAS technology 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., infrastructure inspections) and due to other dangerous activities that can be avoided. ii. Reduces the cost of obtaining such information, which benefits consumers and the economy. iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions 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 manufacturer. All repair and maintenance work will be conducted or approved by qualified personnel such as those authorized by DJI (or equivalent), and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft. c. Al l flight operations will be conducted by at least two individuals (PIC and observer) who will maintain verbal communication capability with each other at all times during the flight, and who will remain stationary on the ground during the flight operations : i. The Pilot In Command (PIC) possess the following credentials: 1. An Airman Certificate issued under 14 CFR 61 (commercial pilot license) screened by the TSA 2. A current Second Class medical certificate issued under 14 CFR 67. 3. A bi

- annual flight review under 14 CFR 61.564. Successful completion of a UAS knowledge test in a specified form.

5. 12,500 hrs of flight experience in manned aircraft. At least 25 hours of flight experience in a UAS rotorcraft (or UAS fixed

-wing in the case of fixed

-wing fl ight operations under this exemption). Such hours may be gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119. 6. At least 5 hours of flight experience and 3 takeoffs and landings in make and model being flown in the 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. ii. A Visual Observer. iii. A Sensor Operator as necessary. d. All flight operations will be conducted in accordance with valid Certificates of Authorization. e. All flight operations will comply with the following: i. The manufacturers’ user manuals. ii. Precision Aero

- Graphics & Imaging’s Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM) which include lost communication and other emergency and safety procedures. iii. Conducted in VMC conditions during daylight hours. iv. PIC and VO will maintain VLOS at all t imes. 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 below 400 feet above ground level. vii. Flight ground speeds will not exceed 50 knots. viii. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place within 5 nautical 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 prio r permission. x. Each flight will be logged in both the PIC’s logbook and the aircraft logbook. xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 20 minutes, whichever occurs first. xii. Any incidents will be reported immediately. xiii . Any applicable local FSDO requirements.xiv. All other applicable regulations concerned with the operation of aircraft.

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well

defined and tested lost link procedures.

P lease advise us of any additional information or changes that may be required. Sincerely, James F. Spicer, owner, chief pilot Precision Aero

- Graphics & Imaging