U. S. Department of Transportation

Docket Management Sy stem 1200 New Jersey

Avenue, S.E. West Building Ground Floor, Room W12

- 140 Washington, DC 20590 **RE: Docket ID: FAA**
**- 2014** 
**- 1081**  Petition for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11.81 of the Federal Aviation Regulations April 24, 2015 **Petitioner:** Brian Stanford 4012 Tenn ys on St. San Diego, CA 92107 Email : brian@stanfordenterprise.com De ar Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11.81, Brian Stanford , hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its small, unmanned aircraft for photogrammetry , photography /cinematography , industrial inspections , search & rescue, and anal ys es . All operations shall be conducted within and under the conditions and limitations outlined previously by the FAA as required by Section 333 and conducted in compliance with the attached operator’s manuals. 1. Sections from which exemptions are sought : Application is hereby made for exemption from: a. 14 CFR Part 21, subpart H b. 14 CFR Part 61.113(a) and (b) c. 14 CFT Part 91: i. 91.103(b)(2) ii. 91.105 iii. 91.109 iv. 91.119 v. 91.121 vi. 91.151 vii. 91.405 viii. 91.407 ix. 91.409 x. 91.417 2. Relief sought :a. Brian Stanford wishes to operate small Unmanned Aircraft Sy stems (sUAS) for commercial purposes to include (but not be limited to) photogrammetry , photograph y/ cinematography , industrial inspections , search & rescue, and anal ys es. This relief is sought because commercial use of sUAS is currently prohibited by

law unless performed under an exemption. b. This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds including payload and energy sources: i. Quanum 680 UC Pro Multi

- rotor (6

- propeller hexagonal frame, carbon fiber): 1. Total weight with maximum allowable payload: 9 lbs. 2. Dimensions: Greatest width: 68 0mm (25.59in ), Height (with landing gear): 305mm 3. Maximum speed: 30kts 4. Battery sy stem (1x 4

- cell, 14.8 volt , 15 ,000maH lithium

poly mer) provides fifteen (15) minutes of flight time, and two (2) minutes of reserve flight time. 5. NAZA

- M Flight Controller (with GPS and comp ass) is installed on this sUAS, and is the most advanced sy stem currentl y available, with latest firmware release. 6. Use of First

- Person View (“FPV”) for advanced flight safet y; provides real

- time video downlink from sUAS as well as critical flight s ys tems status to video monitor on transmitter. ii. HobbyKing H 550 Flamewheel Multi

- rotor (6

- propeller hexagonal frame, plastic/metals): 1. Total weight with maximum allowable payload: 6.5lbs 2. Dimensions: Greatest width: 550mm (21.65in), Height (with landing gear): 10.5” 3. Maximum speed: 30kts 4. Batt ery s ys tem (4

- cell, 14.8 volt, 5 000maH lithium

- poly m er) provides eight (8) to fifteen (15 ) minutes of flight time, and one (1) minute of reserve for RTH function if necessary. 5. NAZA

- M Flight Controller (with GPS and compass) is inst alled on this sUAS, and is the most advanced sy stem currentl y available, with latest firmware release. 6. Use of First

- Person View (“FPV”) for advanced flight safet y; provides real

- time video downlink from sUAS as well as critical flight s ys tems status to vi deo monitor on transmitter. iii. Flight Controller and Fail

- Safe s ys tems: 1. The existing flight control technology that Brian Stanford utilizes is the DJINAZA

- M Flight Controller, which provides these safet y features: a. GPS Attitude Control: Prior to flight operation, the GPS records latitude and longitude, and that position becomes the origin of flight. Once airborne, the GPS holds the sUAS in this position, and does not deviate from it, unless the operator changes the mode. Thislevel of safety safeguards the sUAS, preventing it from drifting away , and posing a potential risk of injury or damage to propert y. b. Attitude Control: The flight controller disables the GPS, and allows operator to control the sUAS in a manner consistent with manual flight. The onboard stability sy stems keep sUAS horizontally stabilized, to prevent erratic flight performance. c. Return

- to
- Home (“RTH”): If the operator, under any circumstances, deems the operation of the sUAS to become a risk to persons, propert y, or the sUAS itself, the R TH command may

be invoked, safely

returning the sUAS to the origin of flight, subsequentl y landing and powering down autonomously . This feature is a design protocol that allows the operator to dismiss operation in the event of his or her inability to contr ol the sUAS, as in with an emergency situation. iv. Other models to be added by future amendment to this exemption. 3. Public benefit : a. Use of sUAS technology to obtain imagery , information and data currently obtained by

use of m anned flight or manual methods: i. Re duces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging failures during stack or bridge inspections). ii. Reduces the cost of obtaining such information, wh ich benefits consumers and the economy

. iii. Reduces environmental impact by eliminating sources of hydrocarbon em issions from manned aircraft. 4. Safety

not adversely

affected : a. Aircraft will be registered and marked in accordance wi th Section 44711 and P art 47 and Part 45, Subpart C. b. Aircraft will comply

with maintenance and inspection requirements of the manufacturer. All repair and maintenance work will be conducted or approved by qualified personnel such as those authorized by Rob otic Skies (or equivalent), and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft. c. All operations will be conducted in accordance with valid Certificates of Authorization. d. All flight operations will comply with the following: i. T he manufacturers’ user manuals.ii. Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM ), which include lost communication and other e mergency

an d safet y procedures. iii. Conducted in VMC co nditions during daylight hours. iv. PI C w ill maintain VLOS at all times. v. Pre

- flight inspections (including ground control station, if any) and safet y risk assessments will be c onducted prior to each flight. vi. Flight altitu des will remain below 400 feet abo ve ground level. vii. Flight ground sp eeds will not exceed 50 knots. viii. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place within 5 nautical miles of an airport. ix. Not be made near persons a s required in 14 CFR 91.119 and not over persons on the ground w ithout their prior permission. x. Each flight will be logged in both the PI C’s logbook and the aircraft logbook. xi. Not exceed 75% of the battery or fuel capacit y of the aircraft, or 30 minutes, whichever occurs first. xii. Any incidents will be reported within 24 hours of occurrence. xiii. Any

appli cable local FSDO requirements. xiv. All other applicable regulations concerned w ith the operation of aircraft. e. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well

- defined and tested lost link procedures. Please advise of an y additional information or changes that may be requi red. Sincerel y,

Brian Stanford