Allen Wilson

1807 Road X Reading, KS 66868

February 3, 2016

U.S. Department of Transportation, Docket Operations West Building Ground Floor Room W12

- 140 1200 New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91 .121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b).

Federal Aviation Administration:

I, Allen Wilson , am writing pursuant to the FAA Moderni zation and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Allen Wilson , an owner and operator of small unmanned aircraft be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Allen Wilson , may operate a small unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”) in accordance with FAA UAS Regulations and Policies.

I hereby formally submit my request for an exemption from the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F. R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). To operate DJI’s following UAS: Phantom 2, Phantom
3, Matrice, and Inspire 1 along with the guidelines of the accompanying DJI Phantom 2, DJI Inspire 1, Matrice, and DJI Phantom 3 operator, safety and maintenance manuals. These UAS will be equipped with detachable cameras and will be transported in proper storage. This proposed exemption would allow me operation of unmanned aircraft systems (UAS) for the purpose of aerial videography/photography as a service to the public/ business interests.

These UASs are multi

- rotor craft weighing no more than 55 lbs including payload. Under normal conditions they operate at speeds of no more than 50 kts and have the ability to hover and move along a vertical a nd horizontal plane simultaneously. The UASs have proven reliable flying capabilities managed by gyro stabilized flight, ground detection (phantom 3 and inspire 1), GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning home and prop guards. This will act to further safety protocols exclusive to lightweight UAS’s specific to video and photography usage as I, Allen Wilson , record flight data and other information gainedthrough permitted flight operations to share with the FAA through any required FAA reports to assists with future protocol and safety regulations.

The requested exemption would permit the operation of the UASs under controlled conditions in

the NAS that would be:

a) limited b) controlled c) predetermined and will provi de safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s responsibility to “...establish requirement s for the safe operation of such aircraft systems in the national airspace system.”

The name, phone number, and address of the applicant is:

Attn: Allen Wilson

Address: 1807 Road X

, Reading, KS 66868

Phone: 913

- 339

- 8753

Email: alw1451 @gmail.com

Specific section or sections of 14 CFR from which I seek relief and the reason I seek

relief:

14 C.F.R. Part 21: Airworthiness Certificates

Given the size and limited operating area associated with the aircrafts to be util ized by I, Allen

Wilson , an exemption from Part 21 meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the reform Act. In all cases, an analysis of these criteria demonstrates that the UA operated without an airworthin ess certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than conventional aircraft operating with an airworthiness certificate without restrictions and conditions proposed.

14 C.F.R. 45.23: Disp lay of marks: general

The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain words or phrases. Further, the two inch lettering is difficult to place on such a

small aircraft with dimensions smaller than the minimal lettering requirement.

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

The FAA has previously declared that additional manned airship experience of a commercially certified pilot would not correlate to the a irmanship skills necessary for similarly proposed operations in previously issued exemptions to this regulation through Exemption Nos. 11062

and 11138.14 C.F.R 91.7: Civil aircraft airworthiness

Currently, since there is no certificate applicable to the UAs in question, this regulation is inapplicable.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on

board this aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the operator.

14 C.F.R. 91.119(c): Minimum safe altitudes

I, Allen Wilson will ensure that UAS do not operate any higher than 400 feet at ground level. I will not fly over congested areas. I will plan operations before hand, for proper flight safety, and proper height analysis as to avoid collisions.

14 C.F.R. 91.121: Altimeter settings

The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety will be achieved by using this.

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The UAS that I will fly are powered by electricity, using lithium polymer batteries that currently have a flight limit of approximately no more than 20 minutes. Therefore, due to the limitations of the batteries, it is currently impossible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required

Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. I, Allen Wilson , however will always fly safely while having the manuals of the DJI Phantom 2, DJI Inspire 1, and the DJI Phantom 3.

14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records

Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. However I, Allen Wilson , will perform preflightinspections of the UAS before each flight as outlined in the operating and maintenance documents. I, Allen Wilson , will also follow manufacturer recommendations from said operating

documents.

**Public Interest**

The use of UAS technology coupled with camera and video capture technology enables a more cost effective means of gathering information than can be achieved with larger and much more expensive fixed wing or rotary aircraft. Additionally, larger aircraft are noisy and much more dangerous due to their size and combustible fuel capacities.

I, Allen Wilson , intend to offer my services, primarily, to public safety agencies for the purposes of collecting aerial imagery for use in supporting those agencies in the performance of their role in serving the community

. 

### Operations will be purely for the benefit of the public and no payment
will be requested for services provided.

Examples of t he use s of the UAS are that these services will :

• significantly improve their ability to conduct size up for fires and locate access and egress
routes for these fires

.

• directly benefit searches for missing persons

.

• 

### a ssist in evaluating flood and wind damage while reducing the danger to first responder personnel.

**Summary**

I, Allen Wilson , am s eeking exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b)

With the exemptions of the mentioned rules I, Allen Wilson , will be seeking to make my UAS photography/videography services available to the public. Alternatively the pu blic had sought to use helicopters and aircraft to achieve what I can offer in a safer, more cost efficient manner. By not using combustible fuel, flying at safe heights and strictly following the operational, safety, and maintenance recommendations from D JI.

These include but are not limited to: ● Flying the following UAS Safely

• DJI Inspire 1

• DJI Phantom 2

• DJI Phantom 3

• DJI Matrice● Flying below 400 feet ● Proper visual inspection of UAS before flights ● Keeping mentioned UAS in visual sight at all times when in operation ● Using an observer to assist if needed ● Remain well clear of and do not interfere with manned aircraft operations, and avoid

other aircraft and obstacles at all times

● Not intentiona lly fly over unprotected persons or moving vehicles ● Contact the airport or control tower before flying within 5 miles of an airport ● Not flying in adverse weather conditions such as high winds or reduced visibility ● Not flying under the influence of al cohol or drugs ● Ensure the operating environment is safe ● Not flying over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, etc. ● Check and follow all local laws and ordinances before flyin g over private property ● Do not conduct surveillance or photograph persons in areas where there is an expectation of privacy without the individual's permission.

Respectfully,

Allen Wilson

1807 Road X Reading, KS 66868

Phone: 913

- 339

- 8753

Email: alw1451 @gmail.com