### Matt Burchfield

Tranquility

Ace Aerial Photography , LL C 1929 L eesburg Dr Clover, SC 29710 May 19 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 2059 0



### Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: 1 ) In spire 1 Safety Guidelines 2 ) Inspire 1 Release Notes
References: 1) FAA Exemption No. 11138, Regulatory Docket 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. FAA20140355 in the matter of the petition of FLYING CAM INC



### Dear Sir or Mad am :

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, Matt Burchfield, request exemption from the following sections of Title 14, Code of Federal Regulatio ns §§

**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, structural inspections of bridges, pipelines, well and cell towers, real estate marketing and surveys and other flight operations that could 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 aircraft. Operations will be performed only at the request of and with the authorization and permission of clients 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 ident ified and proposed by, Matt Burchfield, are drawn from references 13.

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**The FARs** I, Matt Burchfield, request exemption from the above mentioned FARs for the following

reasons.


### 14 CFR 61.113 (a) & **(b):** Private pilot privileges and limitations: Pilot in command. Under **§61.113 (a) and(b)**  private pilots are limited to non

- commercial operations, however I can achieve an equivalent level of safety as achieved b y current regulations because m y UAS does not carry any pilots or passengers. While helpful, a pilots’ license will not ensure remote control piloting skills. The risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined in **14 CFR part61,et seq.,**  I requests an exemption from **§61.113** Private Pilot Privileges an d Limitations.

**91.119(c)** As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer 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 concerning the terms “congested areas” and “densely populated”. I, Matt Burchfiel d, request waiver for this condition to allow reasonable and responsible operations with safety as my main concern in areas of subdivisions and neighborhoods if required.

**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 1 0650. 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 power ed flight. Information provided in 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 specified 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). 91.417(**  **a) & (b)** As discussed in Exemption 11138 (DOUGLAS TRUDEAU), I, Matt Burchfield, propose 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 operat ing 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**

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DJIInspire 1 Quad Manufacturer: DJ I Mo del: Inspire 1 T600 Weight: 2935 g / 6.47 Pounds Passenger Capacity : 0 (unmanned) Size (dimensions): 438x451x301 mm (17.24x17.76x11.85 inches) Max Speed: 22 mps (72.18 fps / 49.21 mph) Max Flight Time: 18

- 25 mins Max Ceiling (software limited): 400 ft AGL Operations: Line of Sight Controller: Dedicated Commercial Controller with 2 km maximum rated operating distance . DJ I Vision Positioning is a positioning sy stem that uses ultrasonic and image data to help the aircraft identify its current position. With th e help of Vision Positioning, the Inspire 1 can hover in place more precisely and fly indoors or in other environments where ther e is no GPS signal available . The main components of DJ I Vision Positioning are located on the bottom of the Inspire 1, includi ng two sonar sensors and one monocular camera. (Inspire 1 User Manual v1.2, 2015)

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 stre ngth, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has fail safe 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 b y the PIC. Battery life limits flight times to approximately 18 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 10 minutes. More information is available in attachment 1.

**Risk mitigation** I, Matt Burchfield, have reviewed FAA exemptions referenc e’s 13 **Conditions and Limitations**  section and believe 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 UAS’s airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components.

I, Matt Burchfield, request that in a manner similar to reference 3, be allowed to operate within 5 miles of an airport provided that. **“The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles**  **of the geographic center of a**  **non towered airport as denoted on a current FAA published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is** 

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**conducted in accordance with a NOTAM as required by the operator’s COA. The letter**  **of agreement with the airport management must be made available to the Administrator upon request.”** 
Operations within 5 miles of an airport are not anticipated to be routine but I am requesting a mechanism to facilitate such ac tivities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack of mode C transponder.

**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.
In regards to performing inspections of bridges, towers, and natural gas pipelines the UAS

w ill minimize the risk to persons attempting to climb these structures and photograph problem areas. It will provide a way for companies to have their engineers review photographs and provide additional safety to the general public in regards to towers fail ing or natural gas pipelines having structural issues. Many of the natural gas pipelines in our area travel in areas that are hard to reach by vehicle or foot and if an area is suspected of having problems the UAS can reach it to make an assessment easier and safer.
I, Matt Burchfield, will also make the UAS and myself available to local volunteer organizations (for no charge) such as fire departments, local law enforcement, etc., to perform search and rescue operations, or other similar events as directed by authorities.

In addition the use of the UAS in 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, ame nities, and benefits of their desired photographic subjects that cannot be displayed through ground level photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance my personal photography. A visual observe r will be utilized at all times that the UAS is performing duties for compensation and the PIC will hold a Private Pilots license. Liability insurance will be obtained commensurate with the granting of this request for exemption.
Flight data including UA S flight time, Control Unit operation time, incident, and details will be recorded for each flight and made available to the FAA at any time needed. Any deviations from normal operations will also be recorded and made available to FAA.

**Conclusion**

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I, Matt Burchfield, am requesting this exemption for the purposes of aerial photography of real estate, bridge inspections, land surveying, pipeline inspections, tower inspections, and other flight operations. The reason for such a general and broad based request is that I, Matt Burchfield, wish to utilize a business strategy in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptions. My business model is based on the idea of offering 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 prevent structural disasters that may influence the general public or individuals.

My own research sho ws an upward demand for these services that currently exists in the real estate market, natural gas market and other markets are just beginning to realize the need for such services.
Several people are offering services such as the above in my area but I have refrained for pursuing commercial use of my UAS until I can properly be authorized by the FAA.


### Thank you for y our time and attention in this most important endeavor.

In His L ovingkindness,

Matt Burchfield
Tranquility

Ace Aerial Photography , LL C