Ruel Boyd Ruel Studios 26362 Spring Creek Circle LakeForest, CA 92630 

### ruel@ruelstudios.com

Date: November 12th, 2015

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SEWashington, DC 20590 '4 __.,**~.:--.,** .:.-.· i.., :· \

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### Petition ofRuel StudiosforExemption Pursuantto Section333 oftheFAAReform Act

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the ReformAct) and 14 C.F.R. Part 11 Ruel Studios, operator ofSmall Unmanned Aircraft Systems ("sUASs") equippedto conduct aerial photography and Videography, News gathering, Aerial Surveying, training, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.1

As described more fully below, the requested exemptionwould permitthe operation ofsmall, unmanned and relatively

### inexpen~ive st.JAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. Theproposed exemption, ifgranted, would allow Ruel Studios to conduct commercial operations ofsmail unmanned aircraft systems ("UAS") meeting orexceeding all ofthe operational and safety requirements Congress has set forth in Section 333. Page 2. Ruel Studios asks thatifanypartofthis request is deemed not in compliance, thatpartberemoved andprocess the remaining ofthis request as applicable.

Ruel Studios is a media/technology company owned and run byRuel R. Boyd. Mr. Boydhas providedphotographs for over a decade to the Real Estate Community. Many ofthe properties
are large estate with substantial acreage. Ithas been extremely costly as well as occasionally difficult to coordinate times for conventional aerial photography due to areadensities and varying weatherconditions. It is Mr. Boyd opinionthatthe use ofsUASs for these application provides an overwhelming safer approach as well as being significantly more cost effective for the consumers. Mr. Boydhas had a passion for aviation from an early age, soloing at age 16. He has 280 hrs in various single engine light aircraft

- BeechcraftMusketeer 19a, Cessna 150/152/172. Hehas also held a Hang Gliding & Paragliding Association rating ofH-5. The majdtity ofhis careerhas been inthe Aerospace industry in various management and engineering·roles. He has contributed to the San Diego Air & Space Musel.nn withhistoric research and publications. Mr. Boyd has been active in Radio Controlled Aircraft·for over 30 years with experience in fixed wing and multirotor aircraft. 

# lRuel Studiosplansto exploit the capabilities ofUnmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- EventPhotographyNideography

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring -News Gathering Statutory Authority Section 333, titled "Special Rules for CertainUnmanned Aircraft Systems", provides a mechanism for seeking expeditedFAA authorization ofsafe civil UAS operations in theNAS. Section 333(a) states thatthe PAA "shall determine ifcertainunmanned aircraft systems may operate safely in the nationai airspace system before completion ofthe (comprehensive) plan and rulemaking required by section 332(b)(1) ofthis Act or the guidance required by section 334 ofthis Act." In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitionermeets all requirements to permit PAA approval ofcommercial UAS operations.

The Petitioner Requests ReliefFromthe Following: Regulations from whichthe exemption is requested: 14 C.P.R. Part 21 14 C.F.R. 45.23 (b) 14 C.P.R. 61.113(a) and (b) 14 C.P.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.P.R. 91.109 14 C.P.R. 91.119 14 C.P.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.P.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.P.R. 91.215 14 C.P.R. (91.401

- 91.417)
Unmanned Aircraft System sUASs are oftentimes seen as superiorto helicopters due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact whichpromotes public safety.

Wearepetitioning for exemptionto enable Ruel Studios to operate the DJI Inspire 1, DJI S900, DJI Phantom 2, DJI Phantom 3 equipped with a three-axis camera gimbal and using a High-Def
camera. These sUAS have a failsafe function ofthe autopilot system which means whenthe communicationbetweenthe Main Controller andthe transmitter is disconnected, the outputs of all command sticks from controller will go to the centerposition. Ifthe GPS signal is good enough, the system will automatically trigger Return to Home and will land safely.Aircraft Gross weights are less than 164 oz. withbattery and the 3 Axis Camera Gimbal and Camera

A Pre-flight inspection will be performedbythe PIC in accordance with the factory instruction manual. An added step will be the inspection ofthe propellers. A propeller will bereplaced ifit has any nicks and cracks with a manufacturers authorizedpropeller.
The sUAS will be maintained in accordance withthe manufacturers instruction manual and only manufacturer's authorized replacement parts will be used.
FCC Information

This transmitters used for controlling the sUAS complies withpart 15 ofthe FCC rules. Operation is subject to the following two conditions: (1) This device maynot cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. The radio transmitters used for controllingthe sUAS is wireless technology whichhas been tested and found to be compliantwiththe applicable regulations governing a radio transmitters in the 2.400GHzto 2.4835GHz frequency range. Antenna SeparationDistance When operating ourtransmitters, the PIC will maintain a separation distance ofat least 5 em betweenhis body (excluding fingers, hands, wrists, ankles and feet) and the antenna to meetRF exposure safety requirements as determinedby FCC regulations.
Pilotin Command and Observer Qualifications and Duties
The PIC will maintain at least a Sport Pilot Certificate and a current Class III medical certificate
or drivers license, plus at least 1hours flying time and 3 takeoffs and landings within the previous 90 days inthe type ofUAS utilized in operations. We understand that currently a Pilot's license is necessary for current commercial drone operators, and will comply fully withthis requirement. The PIC wili have at least 20 hours total time and at least 10 hours flying Radio Controlled Model Aircraft ofwhich will be 5 hours flying sUASs'. Training will be conducted at a local Controlled Access flying field. Ruel Studios has the ability to safely train new sUAS Pilots. The PIC instructor will be at all times be able assume control of the sUAS.
The PIC is responsible for the safe and efficient operation ofthe aircraft. Specific duties include all preflightpreparation, in flight operation, post flight requirements, all procedures including but not limited to: Safe in flight operations Risk Mitigationto Persons and property Airfield SuitabilityThe Observermust have the visual acuity to observe the sUAV and be able to communicate clearly withthe PIC. The Observers duties are; warning the PIC ofany impending obstacles inthe flight path ofthe sUAS. warning the PIC ofany deviations inthe planned flight path ofthe sUAS. warning the PIC should any unauthorized personnel appear inthe area ofthe planned flight. The Observer will have the authority to orderthe PIC to terminate the flight should he feel the flight cannotbe conducted safely.
General Operating Standards
Ruel Studios will only operate its sUAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from hazardous areas. Such operations will insure that the sUAS will"notcreate a hazard to users ofthe national airspace system orthe public."

• Before an operation ofa sUAS within 5NM ofan airport with a control tower, the control tower will be calledto gain permissionto operate the sUAS. The PIC will give the position, altitude and the times the sUAS will be operated. The sUAS will not be operated at an altitude ofover 400 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.

Before an operation ofa sUAS within 5NM ofa non-tower controlled, airport operators will be notified andthe PIC will give the right ofway to avoid flying in the proximity offull-scale aircraft. At no time will the sUAS be operated withinthe final approach course and the takeoff
course ofany runway. The sUAS will notbe operated at an altitude ofover 400 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.

• Maximum flight time for each operational flight will be 30 minutes.

• Flights will be terminated at 25% battery powerreserve should that occurpriorto the 30 minute limit.

• The sUA V will be programmed so that it will be operated at an altitude ofno more than 400 feet AGL.

• Minimum crewfor each operation will consist ofthe sUAS Pilot, and Visual Observer.

• The sUAV operatedbythe petitioner weighs less than 55 pounds, includingthe payload (i.e. camera, lens, and gimbals).

• The sUAV will operate at speeds ofno more than 40 knots, can hover, and can simultaneously
move vertically and horizontally.

• Given the small size ofthe sUAV and the restricted sterile environment within which they will operate, our sUAV operations adhere to the Reform Act's safety requirements.The 

### VAS, poweredby batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people onboard and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time ofonly 20 minutes, this is offers little or no riskto national security.

Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics oflarge, complex properties with several buildings and large trees. The applicants inthe pasthave chartered 1-seatfull-sized helicopters for this purpose, whichhas proven more costly than many potential clients have been able to afford. The benefits ofreduced cost and improved quality ofpresentation from the UA will be valuable to and benefit many buyers and sellers ofreal property as well as mitigating risk by not carrying personnel for flight operations. (a) No flight will be made with a Gross weight exceeding 55 pounds; (b) All operations must occur inFAA allowed Class ofairspace at no more than 400 ft AGL, at an airspeed ofno more than 40 knots and no further than Visual line ofsight from the PIC; (c) All operations mustutilize a visual observer (VO). The VO and PIC mustbe able to communicate by voice at all times during a flight operation; (d) All required permits will be obtained from state and local government priorto operation;

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY
Ruel Studios requests an exemption from the following regulations as well as any additional regulations that maytechnically apply to the operation ofthe sUASs System:

14 CFRPart 21, Airworthiness Certificates This part establishes the procedures for the issuance ofan airworthiness certificate. While the FAAcontinues to workto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued forthe DJI Inspire, DJI S900, DJI Phantom 2, DJI Phantom 3, 3DR Solo under either or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a)Research anddevelopment. Testing new aircraft design concepts, new aircraft equipment,
new aircraft installations, new aircraft operating techniques, ornewuses for aircraft. (b) Showingcompliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance withthe function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crewtraining, we would expectthat an experimental certificate would permit our commercial purpose as well. The aircraft will not carrypersons orproperty, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily ofcarbon fiber and plastic, we propose that the UA will be at least as safe, ifnot safer, than a conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFRPart 21, Subpart H, and the requirement for an airworthiness certificate in general, citingthe equivalent level of safety outlined inthe previous paragraph.



### 14 CFR45.23 Display ofmarks; general and 45.29 Size ofmarks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 

### 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" inletters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUA V does nothave an entrance inwhich the word "EXPERIMENTAL" can be placed, and may nothave a registration number assigned to itby the FAA. We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" inthe placard
onthe top ofthe aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others inthe vicinity ofthe aircraft while it is preparing for launch will be able to
see the designation. Additionally, we feel thatthe permanentplacard discussed inthe previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag, sign orbannerthat contains the words "Unmanned Aircraft inUse" in letters 

### 3 inches high or greater. Since the aircraft will operate within Line ofSight ofthe ground station, the banner shouldbe visible to anyone that observes the aircraft and chooses to investigate its point oforigin.



### 14 CFR61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercialpilot privileges and limitations. The regulation provides thatno person thatholds a Private Pilot certificate may act as pilot in Command ofan aircraft for compensation or hire. Subparagraph (b) allows a private pilotto act as pilot incommand ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to thatbusiness or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Ourproposed operations require that the PIC must hold at least a Sport Pilot Certificate with a Drivers License and since the aircraft cannot carry passengers orproperty, we feel we meet the intent of61.113 Subparagraph (b) eventhough the intent ofthis application is to conduct a business.


### 14 CFR91.7 Prohibits the Operation ofan aircraftwithout an airworthiness certificate. As
no such certificate will be applicable inthe form contemplated bythe FARs, this Regulation is inapplicable.


### 14 CFR91.9 Civil aircraftflight manual, marking, and placard requirements. This regulationprovides that no personmay operate an aircraft unless a current, approved flight manual is inthe aircraft. We assume that the intent ofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemptionto this requirement since the aircraft is not only too small to carry documentation, thedocumentation would not be available to the crew during flight operations. To obtain an equivalent level ofsafety and meet the intent of91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No personmay operate a civil aircraft that is being used for flight instructionunless that aircraft has fully functioning dual controls." Training will be conducted at a local Limited Access flying field. Ruel Studios has the ability to provide" Safe Dual Training". The PIC instructor will be at all times be able assume control ofthe sUAV.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closerthan 500 feet to any person, vessel, vehicle, or structure. Since the typical mission ofthe sUAS would bephotography or survey ofpersons, vessels, vehicles or structures itwouldbe necessary to operate closerthan 500 feet to the items listed. Operations will only be flown over property orpersons where permissionhas been obtained and careful pre-planned flight pathhas beenperformed. The aircraft will be operated at a low altitude allowing, ifa power unit fails, an emergency landing without undue hazard to persons orproperty onthe surface. Therefore we maintain that due to the small size oftheUAS, the hazard to persons, vehicles and structures is minimal comparedto manned aircraft, which should be considered in granting the exemption.

CFR91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below 400 feet AGL and will notneed to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoffpoint is transmitted viaradio from the sUAS on-board computer and coordinated withbarometric pressure sensors onthe base station computerto the display screenheld by the PIC, providing a constantly updated AGL readout.
14 CFR91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no personmay begin a flight in an airplane under day-vFR conditions unless there is enough fuel to fly to the first point ofintended landing and to fly after that for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS is battery operated andthe maximum duration offlight from a single battery charge is 20 minutes with a 25% reserve. Since the aircraft will never fly more than line ofsight from the point ofintended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemptionto the word "fuel" and ask for an equivalent interpretation withthe word "energy".
14 CFR91.203(a) & (b) Civil aircraft: Certifications required.The regulation provides that an airworthiness certificate, withthe registration number assigned to the aircraft and a registration certificate mustbe aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of6.1 pounds, the sUAS is too small to carry documentation, does nothave an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level ofsafety and meetthe intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAAwill be with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft viaplacard containing the following informationplusthe word "EXPERIMENTAL" to satisfy the requirement of 14 CFR45.23.



### 14CFR91.205(a), (b), (c) Instrument and EquipmentRequirements This regulation provides a minimum set ofinstruments and equipmentrequired for day and night VFR flight. Due to the small size ofthe sUAS it wouldbe impossible to carry many ofthese instruments. 91.205 (b) 4,5,6,7,8,13,14,16,17 are not applicable as the sUAS has no Reciprocating engines or seats. 91.205 (b) 2,3,9 are provided onthe handheld controller. 91.205(b) 1is not applicable as the maximum available speed ofthe sUAS is less thanthe maximumrequired by this exemption and has no effect onperformance. 91.205 (b) 10 is not applicable as the landing gearposition can be verified visually before landing. 91.205 (b) 15 Due to the size it would be impossible for the sUAS to carry any known ELT. 91.205 (c) Much ofthis equipment is too heavy to be carried by the sUAS. We feel that visual contact with the sUAS and indications provided viathe controllerthat all critical information canbe monitored.



### 14 CFR SubpartE (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides thatthe operator is primarily responsible for maintaining the aircraft in
an airworthy condition, including compliance withpart 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Itis our intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure thatthe aircraft is in an airworthy conditionpriorto every flight and in addition conduct detailed inspections after every two hours offlight. Maintenance performed bythe PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All othermaintenance willbe performed bythe manufacturer ortheir designated repair facility. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety. 

### Safety and Benefits ofthe UAS Ruel Studios will be using the UAS in a variety ofapplications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad benefits overthe use offull-sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography,justto name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin ofsafety for the pilots and crew.By granting Ruel Studios' requested exemptions, the FAA will help drive development ofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations Ruel Studios is committed to promoting the UAS research efforts ofpolicymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAAhas good cause to grant this Petition.
Conclusion As pointed out inthis application, all the SUAs which our company would use, under authorizationbythe US DOT-FAA, are small, light-weight devices operated within the line of sight ofthe Pilot-in-Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location with aviation activities, unless the air traffic control authorities (ATC) have beennotified and have authorized each flight within a radius ofthis distance.

All our SUAs have proven capability for controlled flight. They are devices offered for general sale on the market around the world and have often been used as Model Aircraft inthe USA. We are certainthatthe studies conducted until now by the FAA, about Section 332, Public Law 112-95,2014, have already provided you withthe assurances onthe airworthiness ofSUAs such as ours.
Forthe foregoing reasons, the exemptions requested herein should be granted Ruel Studios should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate bythe FAA. The submission of this application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some SUAs may be used for legitimate commercial activities and underreasonably safe conditions. Ifany individual aspect ofthis request for exemption be unacceptable we ask that it be struck alone and the remainder ofthe exemption be allowed as requested. Signed



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