Docket ID: FAA

- 2014

- 0481

Douglas Trudeau, Associate Broker Tierra Antiguea Realty 1650 E River Road, Suite 202 Tucson, AZ 85718 Office: (520) 544

- 2335 Mobile: (520) 954

- 2209 Email: Doug@TheTrudeauGroup.com

Supplemental Information for FAA

- 2014

- 0481
UAV/UAS/UA Clarification
The UAV/UAS/UA which Douglas Trudeau , Petitioner, will be operat ing is the DJI Phantom 2 Vision + , referred hereafter as Phantom

. The inherent safety features, sophistication, programmability, GPS navigation, return home capability, airport vicinity n o

- fly feature and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this a much safer UAV for the purposes of this petition. This is a hobby grade radio controlled UAV that has th e capacity for software upgrad es . It is light, less than 3 pounds including battery and camera. Incorporated into the programming of the Phantom is an automatic return home feature that automatically directs the craft back to point of take off should communic ation with the transmitter be los t

. The Phantom has a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight time is 25 minutes. Gross weight is 2.86 pounds.

Th e Phantom has an additional communication link between the camera and craf t on a different rf for a smart phone connection . Allowing the operator or Pilot In Command (PIC) to monitor battery level, altitude (AGL) , distance from PIC, camera imagery, and control camera angle

.
The software for the Phantom allows the operator or P IC to set maximum altitude AGL for each flig ht , allowing customization of flights to no higher than 100 feet, 150 feet , or 250 feet AGL as an example s

. The 400 foot maximum AGL can be programmed into the UAV's software pre

- flight to insure compliance with FAA standards. Adding to the safety cap abilities of this UAV. This UAV is programmed to remain in position when controls are released. Maintaining altitude and GPS location.
The Phantom has an altitude and radar monitoring function that allows the operator more precise determination of height , direction of flight a nd distance from the operator PIC. The operator or PIC can monitor GPS lock status while UAV is in flight, with the ability to anticipate loss of GPS locking so the operator or PIC can land the UAV as a precaution.
Best explanation of the Phantom's sophistication and capabilities can be observed through a vide o explanation of an earlier model that was predecessor to the Phantom 2 Vision + through link http://youtu.be/3mqj

- WBRKmE

. The Phantom 2 Vision + maintains all capabilities defined in the video.Having flown the Blade 350 QX UAV while encountering rf interference, even with the blue tooth turned

off to the GoPro Black 3+ wi th both utilizing the same 2.4 ghz rf has lead the petitioner to abort aerial video/photography use of this craft. Reducing it to strictly hobby use for enjoyment and additional flight experience. T he DJI Phantom 2 Vision +'s 2.4 ghz transmitter/controlle r/receiver rf for managing fl ight with a 5.8 ghz rf transmitter/receiver for video/photography functions eliminates the rf conflict experienced with the Blade 350 QX, and is by far the safer of the two when considering public and NAS safety. Considering the programmability and safety features of this UAV (P hantom 2 Vision +), it serves as the best option to protect the Public and NAS for the purposes of this petition.

Similarities, Distinctions and Differences
Though the petition of Astraeus Aerial (FAA

- 2014

- 0352), referred hereafter as the Astraeus Petiti on and or Petitioner Astraeus , has numerous similarities to that of Douglas Trudeau (FAA

- 2014

- 0481), referred hereafter as the Trudeau Petition and or Petitioner Trudeau , there are some distinct and substantial differences. Like the Astraeus Petition, th e Trudeau Petition is for UAV operation without pilot, passengers nor property on board. Considering that the Phantom UAV is a sophisticated hobby grade quad

- copter with gross weight less than 3 pounds Petitioner Trudeau requests waiver or exemption for a private pilot certi ficate . Aerial video/photography operations for this petition provide service for th os e businesses, transferees, retirees and others considering relocating to Tucson, Oro Valley, Marana, Sahuarita, or Vail who are not familiar with ge ographical characteristic , communities, services and other benefits of the area. Aerial video/photography operations for private property ow ners aide with an enhanced perspective for characteristics, amenities, and benefits a private property has that cannot be di splayed through ground level video/photography. Petitioner Trudeau charges no additional fees for ground level video/photography. Therefore, there is no compensation for these service s. Aerial video/photography represent a small portion of videos and photos currently offered at ground level for the community as well as private properties marketed for sale. Aerial video/photography is an enhancement to videos/ photography already offered homeowners and the public

. In most cases aerial video will represent 4

- 20 seconds of a 2

- 3 minute video.
Petitioner Trudeau is using a UAV that has the capability for ta king off and landing at a single point, identical to a helicopter. There are no runways, aided take off apparatuses, nor routes that need to be flown to area s being aerial video recorded or photographed. Allowing a reduced and more confined area of flight

.

T he Astraeus Petition is for movie sets involving a significant number of people, non

- aerial equipment, moving or action sequences , and a potentially broad geographical area where individuals and equipment may be in motion. Requiring extensive observati on, awareness, coordination and safety precautions. The Trudeau Petition is for video/photography of stationary objects requiring briefer periods for recording in a tightly confined area . The stationary setting of objects poses a significantly lower risks for safety, allowing the operator or Pilot In Command (PIC) to focus primarily on stationary object s for a shorter period s of time. With the movie action scenes, numerous takes may require repeated flights, whereas a stationary object would in most cases require a single flight.Home o wner written consent for aerial video/photography sha ll be obtained prior to fli ght. S igns will be

posted cautioning anyone within vicinity to remain back a minimum of 200 feet. Observer(s) to assist and warn/advise the PIC will be utilized in situations where spectators may be within 500 feet of the flight area.

The single UAV utiliz ed in this petition is a hobby grade quad

- copter that does not require an airman certificate for non

- commercial flight involving less restrictive less regulated flight. Petitioner requests waiver or exemption f rom an airman certificate since this is a sophisti cated hobby grade UAV weighing less than three pounds flown in confined and restricted areas

. Additional waiver or exemption for formal health requirements placed on the Operator or PIC is requested

. Petitioner is an AMA member. UAV flight competency can be verified/obtained through AMA standar ds and procedures.
The motors, rotors, propellers, body/frame, landing pads, etc. for the UAV utilized in this petition are not complicated. Engineering and design allows layman maintenance. Recording part replacement for this UAV may prove redundant due to the simplicity of the craft. Therefore Petitioner requests waiver or exempt ion for maintenance records. However, pre

- flight inspection for cracks, damage or other physical conditions that could hamper safe flight is a reasonable expectation . As well as post flight inspection that may aid in identifying flight conditions that may cause stress to propellers, landing gear, etc

. Thorough inspection of UAV shall be conducted and flig ht response tested should a hard landing or crash occur. Insuring that the UAV can operate in a safe manner before conducting any further video/photography.

Like the Astraeus Petition Petitioner Trudeau requests waiver or exemption for markings due to the small size of the fuselage for the Phantom 2 Vision +.

Petitioner Trudeau requests modification, waiver or exemption and clarification (within reason) concerning section 91.119 prohibition of flight in congested areas . Such restriction puts home owners in subdivisions at a disadvantage by limiting enhanced marketing of their homes; thereby discriminating against them. V ertical takeoff and landing while video recording or photographing a home can allow a n enhanced perspective for view or proximity of mount ains, golf course, manmade lake or other attractions not possible through ground level video recording or photography. Petitioner Trudeau
req uests waiver for this condition to allow reasonable and responsible aerial video/pho t ography in congested areas of subdivisions and neighborhoods.

I n compliance with Se ct ion 90.151 (a) the Phantom is a battery operated UAV/UAS with battery level monitoring capability. Fully charged b attery flight time is rated at 25 minutes, with videos /photos taking much less time to record. Operator or PIC is warned when battery level is low.
Petitioner Trudeau requests waiver/exemption from Section 91.203 ( a) since the Phantom is a hobby grade UAV/UAS that should not require an airworthiness certificate nor a registration certificate. Posting of s pecial flight authorization would not be possible since the P hantom has no cabin and is not large enough to carry a certificate. However, a special flight authorization can be maintained by the operator to make available upon request.