August 19, 2015

Dustin Carlson 309 E Exchange St. PO Box 373 Atkinson, IL. 61235 Email: dcarlson24@gmail.com

U.S. Department of Transportation

, Docket Operations We st Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE , W ashington, DC 20590

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

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 Madam, I n accordance wi th the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, I Dustin Carlson , 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). 91.40S(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, mapping, crop surveying, inspections and other fl ight 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 h erein 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 pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions.

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”. The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required.91.121As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric 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 da ytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered 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 rea ches 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), 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 petit ioner’s operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and record keeping, were sufficient to ensure that safety would not be adversely affected.Risk mitigation:

The petition er 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 ha s been developed and employed to ensure that the UA 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

- p rone components. The petitioner request that in a manner similar to reference 3, he 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 conducted in accordanc e 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 the petitioner is requesting a mechanism to facilitate such activities 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 li eu 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 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, amenities, and benefits of their desired photographic subjects that canno t be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased use of pesticides and fertilizer and conservation of water as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photograp hic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. Liability insurance will be obtained commensurate with the granting of this request for exemption. Flight data including UA flight ti me, 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 submitted to FAA vi a traditional means, e.g. COA Monthly Reports, or other means as required.

The petitioner will be using commercial Small Unmanned Arcraft Systems (sUAS) in the following manner:1) Aerial photography and/or videography for private and/or public use in real estate, land surveying, golf course surveying, crop inspection, and other related commercial activities. 2) Aerial photography and/or videography for television and/or motion pictures, public events, and news gathering. 3) Aerial inspection of residential and/or commercial real estate when contracted by owner. 4) Aerial photography and/or videography to assist with search and rescue operations in case of natural disasters or emergencies when requested by local authorities or government agency in charge

The UAS:

I ’ll be flying the DJI Phantom 2 vision plus is only 44 ounces and is designed to only carry a mounted camera. It’s max speed is 30 knots and can only climb at a rate of 1200 feet per minute. It is equipped with GPS to help make controls user friendly and s tabilize the UAS in spot. It also allows the device to “return home” taking it back to the spot it took off from if the controller looses signal or the device has any problems. It is controlled on FCC certified radio control unit. It’s camera syncs to a ph one to give real time feedback on altitude, GPS, and battery levels. The battery life is approximated at 25 minutes and if the battery levels reach extreme low levels the “return home” feature is enabled.

Conclusion:

I, Dustin Carlson, am requesting thi s exemption for the purposes of aerial photography of real estate, bridge inspections, land surveying, tower inspections, and other flight operations. The reason for such a general and broad based request is that I, Charles Ayers, wish to utilize a busines s 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.

Thanks,

Dustin Carlson