info@orlandonegron.com /	787

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- 34	calle	8		Bayamon,	PR	00959 1 July	1,	2015 Orlando	Negron Orlando	Negron	Photography Flamboyan	Garden F

- 34	calle	8 Bayamon,	PR	00959 Email: info@orlandonegron.com

U. S.	Department	of	Transportation Docket	Management System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

RE:	Exemption	Request	Section	33 3	of	the	FAA	Reform	Act	of	2012

A ttachments: 1 )	Phantom	3	User	Manual V	1.2 (can ’ t	attach it because of	the	size. M ore than	10	MB.) Please,	refer to	this link : http://download.dji

i nnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_e n.pdf 2) Safety Guidelines Disclaimer

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	ADV ANCED	AVIATION	SOLUTIONS	LLC 3) FA A	Exemption	No.	11080	Regulatory	Docket	No.	FAA20140355 in	the	matter	of	the	petition	of	FLYING	CAM	INC

Dear	Sir	or	Madam,

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,	Charles	A.	Brisbane,	DBA	as Charles	A.	Brisbane,	Inc
., 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) ; 91.405(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	the	National	Airspace	System	(NAS)	regulated	by	the	Federal	Aviation	Administration (FAA)	f or	the	purposes	of	aerial	photography,	cinematography,	videography,	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.	NAS	as	compared	to	a	manned	aircraft.info@orlandonegron.com /	787

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- 34	calle	8		Bayamon,	PR	00959 2 Commerc ial	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	aircraft	systems. Operat ions will be conducted within and under the conditions outlined herein 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 majority of this request for exemption will be based on prior Exemption No. 11138 issued to Mr. Douglas Trudeau, Realtor , issued by the Federal Aviation Administration on January 6, 2015, Regulatory Docket No. FAA

- 2014

- 0481 . My request for exemption will utilize the same make and mod el of UAS.

The petitioner, Charles A. Brisbane, is an FAA certificated , Commercial Single and Multi

- Engine Instrument Airplane Pilot with approximately 450 hours

. The Petitioner is also a New York State licensed Real Estate Broker. The petitioner has 6 ye ars ’ experience with remotely operated VLOS Unmanned model aircraft both in single and multi

- rotor UAS ’ s (Draganfly X6).

The	FARs

The petitioner seeks exemption from the above mentioned FARs for the following

r easons ;

61.113(a) & (b) ;

The petitioner requests relief in order to facilitate the utilization of an experienced UAS operator with the addition of a trained observer. All pre

- flight inspection, maintenance and flight logs will be saved and made available to the FAA and Secretary o f Transportation (SoT) for review; with the purpose of safely integrating civil UAS operation in the National Airspace System.

91.119(c)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may requir e 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

“ de nsely populated ” . The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required.

The petitioner will primarily operate the UAS between ground level and 200 feet AGL, but never above 300 feet AGL. The UAS will be operated over designated properties with the

owner ’ s consent and while maintaining a safe distance from persons. The petitioner will compile flight data from the logs. This data may assist the FAA in developme nt of regulations forinfo@orlandonegron.com /	787

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- 34	calle	8		Bayamon,	PR	00959 3 commercial operations in low

- risk, controlled environments.

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 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 ha s 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 18 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 reaches a specified level. Given the limitations on proposed operatio ns and the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable. No UAS operations will be conducted at night, as defined by Federal Aviation Regulations.

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 foun d that adherence to the petitioner ’ s operating 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 U AS

The DJI Phantom 3 is a highly successful consumer grade small rotorcraft in the quad copter configuration with an advertised weight of less than 4 5 Ounces (12 80 g) designed primarily to carry a high definition camera. It has an advertised maximum speed of less than 3 1 knots (1 6 m/s) and a maximum climb rate of less than 984 feet per minute ( 5 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm). 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 andinfo@orlandonegron.com /	787

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- 34	calle	8		Bayamon,	PR	00959 4 telemetry information is tran smitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC o r GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight tim es to approximately 23 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 1 2 minutes. More inf ormation is available in attachment 1.

Risk mitigation

The petitioner 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 will be 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 prone components. These documents will be made available to the FAA and SoT to assist in future implementation of safety standards and regulations. The petitioner will only operate the UAS over designated properties with the owner ’ s consent. Flight plans will be predetermined to limit the UASs flight time and limit safety concerns. The petitioner will take into account distance from persons and potential flight obstacles prior to operating t he UAS. UAS operation will always be within VLOS of the PIC and the observer.

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 air craft 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 cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased comm erce and enhance personal photography. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photographic data for these purposes on a

‘ for hire ’ basis acting as an independent contractor. A visual observer will be utilized. Flight data including UA flight time, 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 via traditional means or other means as required.info@orlandonegron.com /	787

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- 34	calle	8		Bayamon,	PR	00959 5 Conclusion

The petitioner is requesting this exemption for the purposes of “ aerial photography, videography, inspections and other similar flight operations ” . The petitioner's business model is based on the idea of offering ad hoc 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 hobby. The petitioner has refrained from engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance. The petitioner is a Professional Photographer owner of Orlando Negron Photography for more than 10 years and a few years practiced multi

- rotor UAS video and photography as a hobbyist

.

Respectfully submitted,

Orlando	Negron Orlando	Negron	Photography www.orlandonegron.com info@orlandonegron.com 787

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