**BTV Drones Petition for Exemption –**  **Section 333**

July 13 2015 US Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590 Electronically submitted via regulations.gov from: **BTV Drones** 383 College St. Burlington, VT 05401 contact@btvdrones.com (802)448

-0403

BTV Drones is requesting a petition for exemption (Section 333) to fly a SUAS for the purpose of conducting aerial videography and photographing which includes property inspections, aerial acquisition (mapping) , real estate other applicable areas for pre

- planned controlled areas. By u sing a SUAS we can inspect infrastructure and property to find failure points for re

-evaluation. We will also provide opportunities to get aerial views for clients that request us to get cinematography that was previously un

- accessible. By using a SUAS we will be able to assist contractors, home owners, property owners as well as real estate agents at a reduced risk

. We are seeking exemption from several CFR’s as noted below that re main burdensome to BTV Drones doing business and growing. We believe and will provide supporting documentation that BTV Drones can provide a level of safety greater than or equal to the rules we are seeking exemption from. This request is in the public int erest, our interest and our local communities interest here in rural Vermont and New England. We have completed due diligence and have noticed potential impacts from safety to economic impacts to information quality. Aircraft: BTV Drones is currently in t he process of registering (1) DJI Phantom 3 Professional SUAS.The name and address of the application is:

BTV Drones Jordan D. Wires CEO Phone: (802)448

-0403 Email: contact@btvdrones.com Address: 383 College St. Burlington, VT 05401



### BTV Drones currently operates 1 type of registered S UAS and is registering an additional model to the fleet

 DJI Phantom 3 (N383BT)
 Blade 350 QX3 (currently registering)
**Maintenance Inspections** 91.405(a) requires, in pertinent part, that an aircraft operator or owne r shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter. 91.407 (a)(1); prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under § 43.7 of the same c hapter. 91.409 (a)(1) and (2); prescribes that no person may operate any aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 91.417 (a)(b) The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this se ction, have discrepancies repaired as prescribed in part 43 of this chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to out UAS. However, as a safety precaution BTV Drones shall ins pect all UAS before and after each flight. These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepanciesrepaired as prescribed in part 43 of this chapter...,” and others shall inspect or

maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness cert ificate, these sections will not apply. Maintenance will be accomplished by the operator pursuant to the Phantom user manual and guide. An equivalent level of safety will be achieved because these small SUASs are very limited in size, will carry a small pa yload, and operate only in restricted areas for limited periods of time. If mechanical issues arise, the SUAS can land immediately and will be operating from no higher than 400 feet AGL. Further, the operator will ensure that the SUAS is in working order p rior to initiating flight and perform maintenance as required. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. **UAS Equipment** BTV Drones plans to utilize a DJI Phantom 3. BTV Drones will operate the SUAS in a safe manner fully aware of the NAS minimizing risk on both the ground and air. With full VLOS (visual

- line

- of

- sight) and redundant systems on board as well as GPS the SUAS w ill be carefully guided to inspect infrastructure Property. BTV Drones shall officially register the SUAS with the FAA before any flights commence. S UAS are less than 50lbs and fly less than 30 MPH and under 400ft. Flights will be ceased and SUAS will retu rn to home at 20% battery power. A Return to Home (RTH) feature is activated and can be used should connectivity or power issues transpire

. **Radio Frequencies** 2.4 GHz and 5.8 GHz Radio Spectrum Frequencies will be used to communicate and provide live video feeds from the S UAS to a ground station. All frequencies and usage will comply with existing FCC bands. **Procedures Privacy**  All Preflig ht checklists will be followed accordingly. Maintenance and repairs will be logged and batteries will be logged as well. Any potential obstructions in the current environment will be noted. Wind speeds must be less than 15Mph for a safe flight. **Privacy** All flights will occur over private or controlled access property with the property owner’s or controlling authority's prior consent and knowledge. Aerial photography/filming will be of people who have also consented to being photographed or otherwise have agreed to be in the area where filming will take place. **Operation of UAS / Privacy / Public Safety** BTV Drones is aiming to work with clients in the real estate, home inspectors and videography space in primarily Vermont to start. We feel that using a S UAS will complement existing technologies and equipment that is being used today but also provide a greater l evel of safety than alternatives.BTV Drones shall conduct operations in VFR VMC weather during daylight hours

outside of Class B airspace and outside of 5 mile area of Class D/C airport unless approved in the COA. In addition, flight altitudes will be no higher than 400FT AGL. All operations will be conducted line of sight (LOS). We are aware a clearance in the form of a COA will be needed to conduct any operations outside of Class G airspace from the local controlling authority (Tower or FSDO). In additio n any needed NOTAMs will be completed 48 hrs before flights. Possible hazards will be outlined in initial safety briefings and avoided. Hazards can include power lines, tall structures and mechanized moving equipment. “See and Avoid” rules using VLOS will be followed to minimize NAS impacts. Further, permissions must be granted or approved over private or public lands where the UAS is operating. COA will be secured before flights as required by latest FAA guidance. TFRs, NOTAMS, weather etc will all be rec ognized / utilized as applicable. Since the areas being photographed or filmed will be on primarily private property, accessed only after given written and/or oral consent by the property owner(s), and clear of all people, except for the PIC and the PIC's helper(s), approval of this application presents no risk to the public privacy.

We look forward to working together to get this approved if necessary. Please contact us if you require any additional information or clarification.

Respectfully, Jordan Wires, Owner

- Operator

- BTV Drones 383 College St. Burlington, VT 05401