Michael C. Carlini

274 Orchard View Terrace Medford, OR 97504 Cell (541) 326

- 1745

Email: Michael .carlini@gmail.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 1) Ph antom 2 Vision+ User Manual V1.8 2) Phantom 2 Vision Plus (Quick Start Guide)

References:

1) FAA Exemption No. 11138, Regulatory Do cket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

– 2014

– 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20 140355 in the matter of the petition of FLYING CAM INC

May 4 th , 2015

Dear Sir or Madam,

In accordance with the FAA ’ s Guidelines for Submitting a Petition for Exemption under

section 333 of the FAA Modernization and Reform Act of 2012 , I Michael C. Carlini, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§

61.113(a) ; 61.113(b) ; 91.119(c) ; 91.121 ; 91.151(a) ; 91.405(a) ; 91.407(a)(1) ; 91.409 (a)(1) ; 91.409(a)(2) ; 91.417(a ) & (b) ;

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, videography, and other flight operations that could be perform ed 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 aircraft. Operations will be performed only at the request of and with the authorization and permission of

client s or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems.So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by the petitioner are drawn from references 1

- 3.

The FARs

The petitioner seeks exemption from the above

- mentioned FARs for the following

reasons ;

61.113(a) & (b) ;

The petitioner requests relief in order to facilitate the utilization of a n FAA licensed and

current Private P ilot (Michael Curtiss Carlini, Cert # 3571047) with the addition of a

visual observer. All pre

- flight inspection, maintenance and flight logs will be saved and

mad e available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely integrating civil UAS operation in the National Airspace System.

91.119(c)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted close r than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concer ning 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 200 feet. The UAS will be operated over designated properties with the owner ’ s consent and while maintaining a safe distance from persons. The petitioner will compile flight data from the logs. This data may assist the FAA in d evelopment of regulations for commercial operations in low

- risk, controlled environments.

91.121

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the

UAS does not have an altimeter and instead utilizes electronic GPS with a barome tric

sensor for altitude information.

91.151(a)

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to 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 Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of pow ered flight. Information providedin the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specifie d level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced 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 condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner ’ s opera ting documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would not be adversely affected.

The UAS

The DJI Phantom 2 Vision P lus is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted

back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal . Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry and external ligh ting cues before reaching a low battery state. An automatic termination of flight and

controlled automatic landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 12 minutes. More

information is available in attachment 1.

Risk mitigation

The petitioner has reviewed FAA exemptions reference ’ s 1

- 3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be

utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before ea ch flight, maintaining flight and maintenance logs to record time on failure prone components. These documents will be made available to the FAA and SoTto assist in future implementation of safety standards and regulations. The petitioner will only operat e the UAS over designated properties with the owner ’ s 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 o perating the UAS. UAS operation will always be within VLOS of the PIC and the

observer.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS

i n order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Aerial surveying and inspections can increase work site

e fficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photographic data for these purposes on a ‘ for hire ’ basis acting as an independent contractor. A visual observer will be utilized. Flight data including U A flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitte d to FAA via traditional means or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “ aerial photography, cinematography, videography, inspections and other flight operations ” . The reason for such a gene ral and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time

asso ciated with additional exemptions. The petitioner's business model is based on the idea of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in com pliance

.

Respectfully submitted

,

Michael C. Carlini