September 11, 2015

Name and Address of Petitioner: Daniel Olsen 1005 Wy nooski St Apartment 18 717

- 917

- 6491 dholsen@gmail.com

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations 14 CFR, Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l), 91.417(a)&(b)

I, Daniel Olsen , the petitioner, request exemptions in order to legall y operate an Unmanned Aircraft Sy stems (UAS), a DJ I Phantom 3 Advanced , in the National Airspace S ys tem. The DJ I Phantom 3 Advanced this petitioner seeks exemption to use will be referred to as ‘Named UAS’. All flights of the ‘Named UAS’ will be flown b y line of sight (LOS) and performed under 400' above ground line (AGL). The ‘Named UAS’ does have GPS guidance and "return to home" safet y feature installed. The ‘Named UAS’ also uses a smartphone to enhance controls b y sh owing current AGL and visual location of the ‘Named UAS’ to the subject and its surroundings. The petitioner wishes to be granted the exemption for use of the ‘Named UAS’ for commercial videograph y and photograph y of: 1. Residential and Commercial Real Estat e, for marketing the sale of each. 2. Construction Process (Residential and Commercial), providing a visual review of the construction process to be used for marketing of a construction compan y or documentation to be provided to the owner. 3. Property

Survey
, providing a visual review of the propert y to the land owner to be sold, purchased, or prior to construction. 4. Property

Inspection, providing a visual review of existing conditions to the land owner. 5. Property

L andscape, provide visual documentation of ‘bef ore and after’ improvement to a land owner.

The Petitioner believes the use of the DJ I Phantom 3 Advanced is more economical and safe to use than a manned aircraft for the following reasons . In the past, a manned aircraft would be used to provide a visua l review of land and property , which involves pilot fees, inspections, and use of an airport. Use of the ‘Named UAS’ rather than a manned aircraft is more economical to the consumer, and beneficial to the general public due to its small size, low noise, li mited carbon footprint, and minimal potential for accident.

Additionally , the petitioner has purchased $2,500,000 in liability insurance coverage for operation of the UAS. It is also important to note that in order to have a successful business it is in my best interest to be safe. That safety will directly benefit the public because that safet y relates to protecting m y i nvestment in a UAS. If the UAS is damaged, so is my means of providing a service and profiting from it. Also, if I don’t provide a safe service to my customers they will be less likel y to recommend me to their neighbors. So I have to provide a safe service in order to gain the trust of other potential customers.My

request for the following exceptions are based o n those provided to Exemp tion No

. 12795
, 11623, 11650, 11664, and 11734. Ireviewed and quote these public letters because of the similarities to the use of a UAS to capture photograph y and videograph y of real est ate and construction for hire.

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations:

**14 CFR Part 21** Certification Procedures For 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 91.7(a)** Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworth y condition. **REASON FOR EXCEPTION** It has been determined that similar UAS’s do not require an airworthiness certificate, however the petitioner will ensure airworthiness through the combined use of the manufacturer's Operations Manual and preflight checks.

**14 CFR 91.119(c)** Minimum Safe Altitudes:( c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle or structure. **REASON FOR EXCEPTION** The use of ‘Named UAS’ will be flown no higher than 400’ AGL in LOS over developed and developing residential areas that may be considered congested areas. That will not alway s be the

cas e when providing a ‘Propert y Survey’ flight because they could be conducted over empty lots or acreages with no structures. This will minimize the amount of by standers present or in the surrounding area. In the case of flying over or near existing private property while providing a ‘Residential and Commercial Marketing’, ‘Construction Process’, ‘Property Inspection’, and ‘Propert y Landscaping’ landowners will be notified in person by the petitioner, or by

a card left behind by the petitioner, of an occurrin g ‘Named UAS’ flight. The petitioner also proposes to display a caution sign on site while a ‘Named UAS’ flight is ongoing. The petitioner will review with the landowners of associated risks to people and property. Due to the small size of the ‘Named UAS’ the associated risk to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be taken into consideration.

**14 CFR 91.121** Altimeter Settings: **REASON FOR EXCEPTION**The ‘Named UAS’ does not have a barometric altimeter. It does have a GPS that will calculate

altitude. The petitioner will limit flights to a maximum altitude of 400 feet AGL as granted in Exemption No. 12795
, 11623, 11650, 11664, and 11734.

**14 CFR 91.151(a)(l)** Fuel requirements for flight in VFR condition s: ( a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed ( 1) During the day , to fly

after that for at least 30 minutes. **REASON FOR EXCEPTION** The ‘Named UAS’ provides low battery warnings to indicate when you should return the ‘Named UAS” to the launch point. A fail safe automatic landing will occur if the battery reaches critical low voltage. The ‘Named UAS’ will be landed upon the 1st low batt ery alert. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point. All flights will be done during the day and at an appropriat e time as to not be a nuisance to others.

**14 CFR 91.405(a)** Maintenance required: Each owner or operator of an aircraft (a) Shall have that aircraft inspected as prescribed in Subpart E of this part and shall between required inspections, except as pro vided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. **REASON FOR EXCEPTION** The petitioner shall inspect the aircraft prior to every flight. The petitioner plans to follow manufacturer's recommended preflight checklist. Reference given to the Operations Manual.

**14 CFR 91.407(a)(l)** Operation after maintenance, preventive mainten ance, rebuilding, or alteration: (a) No person may operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless (1 )It has been approved for returned to service by a person authorized under 43.7 of this chapt er **REASON FOR EXCEPTION** The petitioner who has the responsibility for the operation and safet y of the ‘Name UAS’ will follow the manufacturer's suggestions for maintenance and repair. Including the use of suggested replacement parts.

**14 CFR 91.409(a)(l ) & (2)**  Inspections: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) An annual inspection in accordance with part 43 of this chapter and has been ap proved for return to service by a person authorized by

43.7 of this chapter ; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may

b e substituted for any

inspection required b y this paragraph unless it is performed b y a person authorized to perform annual inspections and is entered as an "annual" inspection in the required maintenance records. **REASON FOR EXCEPTION**The petitioner will follow manufacturer’s suggestions to ensure that the ‘Named UAS’ is in a

condition for safe flight.

**14 CFR 91.417(a) & (b)** Maintenance Records: (a) Except for work performed in accordance with 91.411 and 91.413, each registered owner or operator shall keep the following records (l)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v)( vi) for the periods specified in paragraph (b) of this section: ( 1 )(2)(3) **REASON FOR EXCEPTION** The petitioner will keep a record of all repairs and modifications. The petitioner also proclaims to use approved manufactured parts for repairs and modifications.

**SUMMARY** I, Daniel Olsen the petitioner request for exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations 14 CFR, Part 21, 91.7(a), 91.119(c), 91. 121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l), 91.417(a)&(b) in order to legall y operate an Unmanned Aircraft Sy stems (UAS), a DJIPhantom 3 Advanced , in the National Airspace S ys tem in order to take aerial video and photography of real estate and construction processes.