View Finder Aerials

Operator: Michael Woodward, PP-ASEL 12835 Muirfield Blvd S Jacksonville, FL 32225 904-357-0336 email: vfaerials@gmail.com

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

Dear Recipient, In accordance with the FAA’s Guidelines for Submitt ing a Petition for Exemption under section 333 of the FAA Modernization and Refo rm Act of 2012, I Michael Woodward, referred to as the petitioner, kindly req uest exemption from the following sections of Title 14, Code of Federal Reg ulations §§

14 C.F.R. 61.113(a)

14 C.F.R. 61.113(b)

14 C.F.R. 91.119(c)

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409 (a)(1)

14 C.F.R. 91.409(a)(2)

14 C.F.R. 91.417(a) & (b)

I the Petitioner seek relief from the listed regulations in order to operate small unmanned aircraft systems (UAS) commercially in air space regulated by the Federal Aviation Administration (FAA) for the purposes of a erial photography, cinematography, videography and other aerial operat ions that can be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned ai rcraft. Safe UAS operations conducted within FAA guidelines will support local business and create positive awareness in the community by providing UAS alternatives to previous methods of larger, more dangerous aircraft. Compensated tasks will be conducted only at the request of and with authorization and permission of clients or their authorized agents in compliance with privacy laws and FAA Regulations

.The FARs

I, the petitioner seek exemption from the above men tioned FARs for the following reasons;

61.113(a) & (b)
The petitioner requests relief in order to facilita te the utilization of an experienced UAS operator with the addition of a trained observe r. All pre-flight inspection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely integrating civil UAS operation in the National Air space System. The petitioner will conduct flights as the authorized UAS Operator . The UAS controlled by the Operator will perform at altitudes well below the p ermissible limits for other civil aircraft, eliminating the risk to other aircraft.

91.119 (c)
As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UAS be operated closer than 500 feet to essential persons, or objects that woul d not be possible without additional relief. The petitioner requests modification, waive r or exemption and clarification concerning the terms “congested areas” and “densely populated”. The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required . The petitioner will primarily operate the UAS between ground level and 400 feet. The UAS will be operated over designated properties with the consent of the local municipality or their designated agent and while maintaining a safe distance from pe rsons.

91.121
As discussed in Exemption 11138 (DOUGLAS TRUDEAU) i s inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. Altitude informati on is generated by the UA on board computing system, it’s then received and displayed at the operators ground station.

91.151(a)
As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft t o operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption N os. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery p ower remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents dis cusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure whe n battery remaining reaches a specified level. Given the limitations on proposed operations and the location ofthose proposed operations, The FAA found that a red uced minimum power reserve

for flight in daytime VFR conditions was reasonable

. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.4 17(a) & (b)
As discussed in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure that the UAS is in a conditio n for safe flight in accordance with the operating documents. The FAA found that adheren ce to the petitioner’s operating documents and the conditions and limitations specif ied, describing the requirements for maintenance, inspection, and record-keeping, we re sufficient to ensure that safety would not be adversely affected.

Areas of interests for UAS commercial use
Aerial video and or photography for real estate, ar chitecture, agriculture, land surveying, engineering, television, cinematography, and news media. Aerial inspections and or photography of residential, comm ercial or industrial structures, utility infrastructures including but not limited t o electrical power lines, wind turbines and cell towers. In addition, live streaming aerial video in efforts assist in search and rescue operations ONLY at the legal authorization o f local authorities or government.The UAS

The petitioner seeks exemption to operate UA Multif unctional Quad-rotor Systems by DJI ( DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 ) for compensation or hire within the National Airspace System. The DJI Phanto m 2, 3, and Inspire 1 are highly successful consumer grade small rotorcraft in the quadcopter configuration. They are vertical takeoff and landing (VTOL) UAS with a Grou nd Control Station (GCS) utilizing an electronic tablet. All 3 systems conta in internal measuring units (IMU) with integrated barometric sensors augmented with g lobal positioning systems (GPS) to maintain their geospatial orientation and positi on. Real time video control station allows the operator and/or PIC to monitor battery l evel, GPS signal strength, altitude, and distance from PIC, camera imagery, and control camera angle. Integrated failsafe mode Return to Home aid and assist operations for e ither loss of RC or GPS signal. The onboard flight controllers will warn the pilot via telemetry and external lighting cues before reaching a low battery state. The 3 UAS s have the capability to abort a flights and return to home safely in case of any un predicted obstacles or emergencies.

DJI Phantom 2

Dimensions: 210x335x335 mm Weight: 1000g / 2.20lb Intelligent Flight Battery: 5200mAh 25min Flight Ti me Max Flight Speed: 15m/s or 33.5mph Operating Frequency: 2.4GHz ISM Key Features: Live real-time flight data Intelligent Orientation Control (IOC), GPS, and Return to home failsafe Self-tightening locking Propellers Dynamic home point orientation Intergraded No Fly Zones prevents inadvertently ent ering protected air space Intelligent Flight Battery includes capacity data, over charge/discharge protection and maintenance data.

DJI Phantom 3

Dimensions: 203x330x457 mm Weight: 1280g / 2.8lb Intelligent Flight Battery: 4480mAh 23min Flight ti me Max Flight Speed: 16m/s or 35.7mph Operating Frequency: 2.400~2.483 GHz Key Features: Live real-time flight data Intelligent Orientation Control (IOC), GPS, and Return to home failsafe Self-tightening locking Propellers DJI Vision Positioning System for improved safety Dynamic home point orientationIntergraded No Fly Zones prevents inadvertently ent ering protected air space

Intelligent Flight Battery includes capacity data, over charge/discharge protection and maintenance data.

DJI Inspire 1

Dimensions: 438x451x301mm Weight: 2935g / 6.47lb Intelligent Flight Battery: 5200mAh 18min Flight ti me Max Flight Speed: 22m/s or 49.2mph Operating Frequency: 5.725~5.825 GHz; 2.400~2.483 G Hz Key Features: Live real-time flight data Intelligent Orientation Control (IOC), GPS, and Return to home failsafe Self-tightening and locking Propellers DJI Vision Positioning System for improved safety Dynamic home point orientation Intergraded No Fly Zones prevents inadvertently ent ering protected air space Intelligent Flight Battery includes capacity data, over charge/discharge protection and maintenance data.Risk Mitigation

Aerial Safety is of the utmost concern. I the petit ioner have reviewed FAA exemptions reference’s 1-3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utiliz ed in order to manage and mitigate risk and ensure public safety. A preflight checklis t is being developed and employed to ensure that the UA airworthiness and will be verifi ed before each launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs. Th ese documents will be made available upon request to assist in future implemen tation of safety standards and regulations. The petitioner will only operate the U AS over designated properties with the clients consent. Flight plans will be predetermined to limit the UASs flight time and limit safety concerns. The petitioner will take into account distance from persons and potential flight obstacles prior to operating the UAS. UAS operations will always be within VLOS of the PIC and the observer.

Developing Flight Check List

On hand DJI Phantom 2, DJI Phantom 3 and DJI Inspir e 1 official Manuals and procedures Reference B4UFLY Smartphone App Optimal weather conditions have been verified Location scouting including landing and takeoff dis tance Establish reasonable low altitudes to ensure safety of civil aircraft Obtain consent of all persons involved in filming i ncluding land and property owners Visual Inspection of aircraft Prepare flight logs Flight battery and transmitter battery at full char ge Propellers are in proper airworthy conditions and a re securely locked and mounted. Perform sensor and compass calibration DJI Ground Station activated Clear uninterrupted communication between UAS and r emote Visually inspect and ensure all motors are running properly and rotate evenly. Ascend 10ft for control inspections: Forward, Back, Left, Right, Hover. Visually inspect for controlled flight performance along with ground station data. Flights will be operated within line of sight of a pilot and/or observer. Maximum flight time for each operational flight wil l be no more than 30 minutes. Flights will be terminated at no less than 25% batt ery power reserve should that occur prior to the 30 minute limit. Flights will be operated at an altitude below 400 f eet AGL, and not more than 200 feet above an elevated platform from which filming is pl anned. Upon completion of flight operations perform visual inspection Record all flight data into the Flight Logs Perform regular scheduled maintenancePublic interest

Choice of UAS over a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operati ons conducted with manned aircraft of greater proportions, carrying a crew an d flammable fuel. Additionally, the use of the UAS in order to facilitate commerce coul d lead to economic growth. Operations for this petition will enable service fo r property owners or their designees seeking an enhanced perspective for characteristics , amenities, and benefits of their desired photographic subjects that cannot be displa yed through ground level videography/photography. Crop surveying application s could lead to decreased use of pesticides and fertilizer and conservation of water as well as increased crop yields and decreased costs. Aerial surveying and inspections c an increase planning efficiency, improve resource estimations, and reduce risks to p ersonnel and property. The petitioner will provide clients with photographic d ata for these purposes on a ‘for hire’ basis acting as an independent contractor. Flight d ata including UA flight time, Control Unit operation time, incident, accident, and detail s concerning any deviations from normal operations will be available upon request fo r use in collecting data regarding the use of UAS as part of these applications.

Conclusion

The petitioner is requesting this exemption for the purposes of aerial photography, cinematography, and videography. The petitioner wis hes to provide safe and reliable services for businesses such as but not li mited to, real estate, architecture, agriculture, land surveying, engineering, televisio n, cinematography



### , and news gathering. By providing safe deployments and cost e ffective operations through UAS the petitioner offering a much needed and desir ed service in the community. The petitioner can ensure adherence to standards an d protocols and can develop and refine generally applicable safety guidelines and p rocesses. The primary purpose of seeking this exemption is to obtain the capability to offer UAS services while remaining in compliance with FAA regulations. The p etitioner has 4 years of experience in the UAS and radio control model aircr aft hobbies and wishes to move forward in this ever growing industry.

Respectfully Submitted,

Michael Woodward, PP-ASEL