Matthew Jensen

39558 Hwy 92 Crawford, CO 81415 August 2, 2015 Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, the following is a petition for an exemption, allowing operation of an Unmanned Aircraft System (UAS) in the National Airspace System (NAS). Specifically, I request exemption from the following regulations:

• 14 C.F.R. Part 21, Subpart H • 14 C.F.R. Part 27 • 14 C.F.R. Part 45 • 14 C.F.R. §61.113 • 14 C.F.R. §91.105 • 14 C.F.R. §91.109 • 14 C.F.R. §91.119 • 14 C.F.R. §91.121 • 14 C.F.R. §91.151 • 14 C.F.R. §91.405 • 14 C.F.R. §91.407 • 14 C.F.R. §91.409 • 14 C.F.R. §91.417 Intended UAS Operations The UAS will be used for • Aerial photography and videography for real estate marketing. • Agricultural inspection to include searching for lost livestock, inspecting irrigation systems, and inspecting crops. The uses above are in the public interest. The use of the UAS for real estate marketing will allow for more properties to be viewed at a lower cost. Searching for lost livestock will save significant amounts of time riding on horseback. Finally, inspection of irrigation systems and crop fields will remove the need for transportation. UAS Description The UAS to be used under the proposed exemption is a Phantom 3 Advanced, manufactured by DJI. This quadcopter has a weight of 1280 g (2.82 lbs) (with battery) and a diagonal size of 590 mm (23 in). It has a maximum speed of 16 m/s (36 mph) with no wind. The maximum battery life allows for approximately 23 minutes of operation. The Phantom 3 Advanced operates in the 2.400 GHz-2.483 GHz frequency range. The Phantom 3 Advanced includes a GPS receiver, which allows the UAS to “Auto-Return Home,”whereby the UAS will return to the take-off spot when directed or when the battery is running low.

The Phantom 3 Advanced also has visual and acoustic sensors, that allow it to identify its position and move accurately. Exemptions 14 C.F.R. Part 21, Subpart H Given the size, weight, performance limitations, and proposed operating conditions listed below, it is argued that the UAS does not create a hazard to the users of the NAS or national security. For this reason, it is further argued that an airworthiness certificate does not need to be issued as required per 14 C.F.R. Part 21, Subpart H. 14 C.F.R. Part 27 The UAS does not meet the performance requirements of 14 C.F.R. Part 27. Again, it is argued that failure to meet these requirements does not create a hazard due to nature of the UAS and operations planned. 14 C.F.R. Part 45 The size of the UAS does not allow for the markings required by 14 C.F.R. Part 45. 14 C.F.R. §

61.113 Despite 14 C.F.R. §61.113, it is requested that a private pilot use the UAS for commercial purposes. 14 C.F.R. §

91.105 The crewmember station criteria of 14 C.F.R. §91.105 does not apply, as crewmembers are not in the UAS. 14 C.F.R. §

91.109 The flight controls required by 14 C.F.R. §91.109 are not met by the proposed UAS. 14 C.F.R. §

91.119 It is argued that the minimum altitudes of 14 C.F.R. §91.119 due not apply due to the nature of the UAS.14 C.F.R. §

91.121 The UAS does not have an altimeter as required by 14 C.F.R. §91.121. However, the Phantom 3 Advanced does have visual and acoustic sensors that allow it to determine its elevation. Also, it is argued that the proposed operations listed below allow for safe operation of the UAS without an altimeter. 14 C.F.R. §

91.151 The maximum battery life of approximately 23 minutes does not allow for the VFR minimum fuel requirements of 14 C.F.R. §91.151. 14 C.F.R. §

91.405, § 91.407, §

91.409, and §

91.417 As described below, it is proposed that preflight inspections and test flights be conducted to ensure that the UAS is in proper operating condition. Proposed UAS Operations In leu of the regulations sited above, the UAS is to be operated per the following: Operations will be conducted within the United States. The pilot-in-command (PIC) will hold a Private Pilot certificate. The UAS will be operated within the visual line of sight (VLOS). An observer shall accompany the PIC. The UAS will not operate at a ground speed exceeding 87 knots. The UAS will maintain a distance of greater than 500 feet from nonparticipating persons, vehicles, structures, or vessels. The UAS will not operate at an altitude higher than 400 ft above ground level. The UAS will be inspected prior to flight to ensure safe operation. A flight test will accompany any major maintenance performed on the UAS. Maintenance of the UAS will be per the Phantom 3 Advanced Operator's Manual. Operations will not be conducted within 5 nautical miles of an airport, unless a letter of agreement is obtained from the airport's management. All operations will be conducted over private or controlled-access property with permission from the owner/controller or their representative.The PIC will abort the flight in the event of unpredicted obstacles, emergencies, or inclement weather.

Operations will not be conducted at night. Summary By following the operations listed above, the requested exemptions for the proposed UAS do not create a hazard to the users of the NAS or national security. I thank you for you consideration. Best Regards, Matthew Jensen