**Docket Number: F AA** 
**- 2015** 
**- 2640**  **11 .81a**  September, 20, 2015 ; formerly submitted June 3, 2015 John E. Tr emba DBA Straight Up Photograph y 404 Stadium Road Connellsville, P

A 15425 724

- 366

- 7767 jatremba@cvzoom.net 724

- 366

- 8485 Federal Av iation Administr ation www .regulations.gov
Dear F AA: Brittany

Newton: Thank y ou for giving me the opportunit y to modify m y petition.
I am requesting an exemption from specific rules within the F AA Modernization and Reform Ac t 14 C.F .R. 1 1 section 333. for aerial photograph y and cinematograph y utilizing light weight sUAS in the industrial inspection (pipelines, windmills, power lines, buildings), private real estate promotions, and closed set major motion picture / television recording. **11 .81b**  The regulations from which the exemption is requested are as follows: 14 C.F .R. Part 21 ; 45.23(b); . 61.1 13(a) & (b); 61.101 9e) (4) (5); 61.23; 14 C.F .R. 61.133(a) ; 91.7(a); 91.9(b)(2) & (c); 14 C.F .R. 91.103 ; 14 C.F .R. 91.1 19 ; 91.151(a) ; 14 C.F .R. 91.203(a) & (b) ;91.405(a); 91.407(a)(1); 14 C.F .R. 91.409(a)(2) ; . 91.417(a). Section 1 1.81 What information must I include in my

petition for exemptions.
**11 .81 c**  My company owns three UA

Vs, a DJ I Phantom 2 vision Plus, Phantom 3 , and Inspire 1. All three are under 7 pounds in gross weight, will not fl y an yw here near 100 mph., have GPS homing devices, battery volume controls, non zoom cameras, ability to fl y in up to 30 mph winds, and use specific frequencies for radio transmissi ons. These and all the other specs of m y vehicles can be viewed in the attached links. http://m.dji.com/product/inspire

- 1/spec http://m.dji.com/product/phantom

- 3

- professional/spec 45.23 (b): In reference to the size and speed of my UA Vs I would expect relief from the requirement of aircraft registration and all the accompan yi ng letters and numbers on m y craft. Additio nally , the words “experimental”, “restricted”, et al. W ould not be necessary

and therefore relieved.
I am asking for relief from Sections 61.101 (e) (4) (5), 61.1 13 (a) (b) as I am not a certified private or commercial pilot. My

piloting skills reflect 20 y ears of fl yi ng remote control aircraft of all sorts and engine ty pes. I know the capabilities of m y three UA Vs and fl y within those parameters. As you can see from the descriptions of my vehicles they

are quite small compared to manned helicopters an d/or airplanes. Manned aircraft over a closed set movie scene poses a definite hazard to an y or all who work under them. Fuel leakage, noise, risk to on

- board pilots and passengers, occup yi ng higher levels of the NAS all lead one to believe that UA Vs are much safer, less expensive of an investment from themovie makers or others employing the craft, and more convenient for the total process whether it is

inspecting windmills / industrial sites, real estate, or making movies. I am currentl y enrolled in UA V University

having completed the first half of the course for UA V pilot certification and soon to complete the flight portion. Because I own a valid Pennsylvania drivers license representing a medical card, I feel I should get relief from sections 61.23 a s well. 61.133; Ineed relief from having to be a commercial pilot in order to be PIC. 91.7(a): Limited relief; As the PI C I still have the responsibility to cancel a flight for an y structural, electrical, or mechanical reasons I see fit. 91.9(b) (2): Limited relief needed; manuals and markings are downloaded and available in UA V carryi ng cases 91.9(c): If I get relief from 45.23 then 91.9 becomes moot.
91.103 L imited relief. Before any flight for any

occasion there is alway s a check of w eather, including wind, precipitation, battery limiting cold temperatures, and LOS visibility

. 91.1 19 Relief from this parameter in that it limits minimum altitudes referencing large manned aircraft as opposed to 3

- 7 pound UA Vs limited maximum altitude

. 91.151 Change these parameters to fit UA Vs. M y three vehicles all have “return home” GPS capabilities and battery

reserve recognition. LOS loss is also a return home feature of the DJ I machines. 91.203 Several portions of this section need rel ieved. Manufacturers (DJ I) always inspect and pre

- fly all their products before declaring them airworth y outside the realm of the normal manned aircraft inspectors. Normal warranties should suf fice as “posted” certifications inside the aircraft.
91.40 5 The same relief is needed for this section as described in 91.203
91.407 91.409 91.417 All portions of these sections refer to inspections and following manufacturer rules Manned aircraft undergo periodic inspection by outside certified mechani cs while the new UA V industry depends upon the operator PI C to do all inspections and manufacturer endorsed maintenance including parts that fail at certain hours of use and circuitry that needs revamping after set hours of operation. Posted certificates may not be available in the UA V world. Limited relief is requested here to exchange normal manned aircraft postings to be super ceded b y UA V manufacturer rebuilds and returns for maintenance. **11 .81d and e narrative**  When inspecting industrial objects the re is no one near the operation of the aerial vehicle. Most objects are set in rural locations (forests/ mountain tops). I operate with LOS only

and record data separately from the fl yi ng machine controls. I have been fl yi ng RC planes and copters for ove r 20 years and have a great feel for the machines. The tallest windmills are under 400 feet. I do pre

- flight inspections and alway s conform to the action at hand with safet y m y first goal. I am the onl y P IC

. Daylight is my

onl y operating environment. Never am I within 5 miles of an airport.The jobs that Icould perform for energy generating companies, oil and gas line distribution, rurally based high tension electric lines, real estate inspections and industrial business building survey s are all in great demand b y the public in various and subjective ways. W indmills require either dangerous man lifts, expensive cranes, or human climbers to inspect the turbines of windmills risking injury and requiring costly

time and machines. Lightweight UA Vs such as th e ones I own are perfect for those inspection jobs and when considering the risk involved at least as safe if not safer than traditional methods. No other people would be around the windmill except me, the PIC, and a windmill technician who would be aware of all dangers and safet y practices such as predetermined flight plans and safety hats, goggles, etc. . Cost and time savings might be passed on to customers. Much of the damage noted by the UA V could be repaired long before it became chronic and debilitat ing to the machines, pipes or wires. The industrial companies have obvious benefits, but some other industries would run more efficiently as well using UA Vs. TV and radio stations could inform their patrons of detours to escape road hazards, accidents, an d construction. Fire fighters could assess damage to burned out warehouses and forests before sending in human resources. Search and rescue ef forts can be magnified by the use of drones. Hard to sell large acreage plots can be displayed online for prospe ctive clients of real estate companies. Potential home or commercial building purchasers can inspect roofs and chimney s as well; All from the safet y of their homes. A variet y of sensors other than cameras can be added to UA Vs for infra red, sound, vibrat ion, electrical, and a bev y of other signals important to our highly technical society . Small businesses can reap the harvest of potential customers seeing the establishment from the air especially

if the business is in a dif

ficult to navigate neighborhoo d. All of these services can be accomplished with little or no hazard to people on the ground if permission and warnings are secured. Before and while I am operating my photography

business, Ihave been employ ed in the burgeoning major motion picture bu siness in Pittsburgh, P A. For the last 7 y ears I have been a member in good standing of IA

TSE local 489 as a movie grip. I am familiar with all safet y procedures taken while recording major motion pictures. No matter how intricate a stunt or scene every o ne on set is tuned to the safe operation and completion of the scene. Recently , Ihave been asked to record several scenes from my UA Vs b y a number of production companies, the most recent, Sony Productions, on the new TV series, The Outsiders. Although I am capable of working well within the realm of safet y our organization requires, and I possess an IRS EIN number (47

- 2705246) for my compan y, a Pennsylvania Dept. of State business entity number (4323628), and a 2 million dollar liability insurance poli cy (W estfield BOP

3546907), I have declined to tape the scenes because I am not permitted under FAA rules to perform such services. The director has assured me that everyone who is on the set or near it would be fully

notified of the flight plans and the area af fected. All safety

procedures would be in place. Practice flights would be flown to rehearse and look for potential problems. Eventually , the compan y found a pilot from Kentuck y with an F AA exemption to tape the scenes I mentioned. The safet y measures taken those day s were bey ond any thing I have witnessed in the movie business these past 7 y ears. I am requesting an exemption from those rules and sections so that Ican practice m y photograph y profession. Movie patrons and TV viewers would enjoy

and critique the scenes as would the artists controlling the sets. Manned helicopters or fixed wing aircraft are thousands of pounds heavier than m y UA

Vs, use liquid flammable fuel, make ear splitting noise and disturb the ground area near the scene with turb ulence. The manned aircraft are just that: manned. If there is an accident pilots and passengers get hurt or killed not to mention people on the ground. If a 5lb. Drone crashes in the forest where no one can hear it, does it reall y make a noise?
Amon g others my

exemption requests are for the requirement to have an airworthiness certification because DJ I has an excellent reputation for quality products and verifiable testing. I request an exemption for having an airman certificate. Because there are n o set F AA rules about pilot licensingfor UA

Vs I enrolled in the UA

V Universit y in Phoenix AZ. I completed the first half of the certificate program, an online course revealing all the diversity of UA Vs and how a number of sensors can be used for data transfer along with safet y and best practices. The second half is a three day practicum in Florida where I could prove my experience and skill set to the instructor . That class is somewhere in my future as I am consumed by m y work and business at this time. Thank you for your time and consideration. Sincerely ,

John E. Tr emba, Straight Up Photograph y