PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 1

December 18, 2015

Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department of Transportation, Docket Opera tion West Building Ground Floor Room w

- 12

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



## Petition for Exemption

RE: Petition of Michael Frey for an Exemption under Section 333 of the FAA Modernization
and Reform Act of 2 012 and from certain rules of 14 C.F.R.

Dear Sir or Madam:

The followin g is a Petition for Exemption relating to Section 333 of the FAA Modernization and Reform Act of 2012. Specifically, this Petition for exemption is filed by DMZ Marketing, LLC., on b ehalf of Michael Frey for exemption from certain rules of 14 C.F.R. Michael Frey requests Exemption in a n effort to be granted permission to operate small Unmanned Aircraft Systems (“sUAS”) com mercially in the
United States of America. These operations would be subject to the current rules and regulations , not stated herein as rules requested for exemption under Section 333, under the jurisdiction of the Department of Transportation and the Fed eral Aviation Administration

. Additionally, all operations will adhere to str ict safety rules enforced by Michael Frey within his

company

. These safety rules will be modeled after recommendations made by the FAA and commun ity

based organizations such as the Academy of Model Aeronautics. Specific conditions relating to the safe operations of sUAS by Michael Frey will be covered in more detail in the documentation to come, however basic flight safety parameters often cited by organizations such as the Academy of Model Aeronautics will be closely followed, such as operations at low altitudes and adequate distances away from airports, heliports, and approach areas to name a few.

As was establishe d in Huerta v. Pirker

, an aircraft is, “any” “device” that is “used for flight.” 1 Clearly this broad definition encompasses the types of sUAS the petitioner, Michael Frey , plans on flying

comme rcially wit hin the United States and as such, are governed by the rules of 14 C.F.R. Due to this, in Petitioner Name: Michael Frey Petitioner Contact: Michael Frey Petitioner P hone Number: 661

- 808

- 0497 Petitioner Email Address: mike@buttonwillow.com Petitioner Address: 11908 Tilbury Way Bakersfield, California 93312

Document Preparer : DMZ Marketing, LLC. Contact Person: Zach Fiene Phone Number: 608

- 370

- 2858 Email Address: dmzaerial@gmail.com Website: www.dmzaerial.com Address : 1501 Parkview Court Prairie du Sac, WI 53578 USAPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 2

the following Petition for Exemption and associated documentation, Michael Frey will establish clear reasoning as to why hi s particular commercial sUAS flights should be granted exemption and why his business should be exempt from certain parameters of 14 C.F.R.

A s has been established by the FAA ov er the last year, sUAS pilots are allowed to petition for exemption
from cer tain aircraft rules that may be inapplicable to sUAS craft or that may place an undue burden on a peti ti oner looking to turn their sUAS hobb y into a commercial business. Michael Frey would like to request exemption from cert ain parameters contained in 14 C.F.R. The specific rules for which Michael Frey requests exemption will be covered in further detail in the documentation to come, but, in

summary, Michael Frey looks to be exempt from the types of rules that may limit or otherwise prevent
his intent of operating sUAS commercially within the United States.

Furthermore, t hese commercial operations would only be conducted after a granted Section 333 Exemption and within the outlined conditions below or that may be otherwise highlighted by the Federal Aviation Administration in their Exemption Approval Letter

. With the approval of this exemption, Michael Frey will be allowe d to comme rcially operate his sUAS within the United States of America. Specifically, Michael Frey will be allowed to fly commercially with
the DJI Phantom 3 Professional

, DJI Inspire 1

, DJI Matrice 100

, Immersion Vortex 250 Pro

, and TILT Pro

. Furthermore, Michael Frey will be opera ting his sUAS in furtherance of various applications within the following industries; Agriculture

, Cinematography

, Environmental Protection

, Fire

, Insuranc e , Land Inspection

, Real Estate

, and Search and Rescue

. Details of these flight crafts; their manuals, safety parameters, operational checklists and more, along with these sUAS flight applications, will be expanded upon in more detail below.

In addition to Michael Frey ’s Petition for Exemption pertaining to the use of the aforementioned aircraft
and use

- cases, the granting of this Petition will also allow for the commercial operations of sUAS in Clas s G Airspace, below 400 feet Above Grou nd Level (“AGL”) , nationwide, or as otherw ise granted in a Certificate of Authorization (“COA”). To start, Michael Frey will adhere to the blanket Certificate of Authorization that is granted to each entity receiving an Exem ption Number. This COA currently allows for flights nationwide, in Class G Airspace, below 200 feet AGL. 2 Further flight areas sought by Michael Frey will be applied for through the FAA’s COA Portal. Additionally, with the potential hazards and
obstacles associated with low

- altitude flight

, Michael Frey will adhere to the Visual Flight Rule (“VFR”) minimums which apply to this airspace. Further details on these operational minimums will be
discussed in the documentation to come.

The Petitio n for Exemption below provides details relating to the proposed applications of commercial sUAS use by Michael Frey

. Specifically, Michael Frey seeks exemption in an effort to conduct commercial operations within the following industries; Agriculture

, Cinematography

, Environmental
Protection

, Fire

, Insurance

, Land Inspection

, Real Estate

, and Search and Rescue

.

In addition to the v ariety of Industry applications highlighted above, this P etition for Exemption will also cover details on various methods of operation and sensor/imagery types for the various applications. Specifically, Michael Frey will incorporate a variety of sensor pay loads on his sUAS in an effort to capture necessary imagery or data types for each specific application or use

- case. Examples of the payload technologies used on the sUAS include, but are not limited to; Visible Light Spectrum Imagery, Near Infrared ( “ NIR ” ) Imagery, Thermal Infr ared Imagery, LIDAR, Se nsor Technologies , GPS Guidance,PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 3

Photogrammetry, Semi

- Autonomous and Autonomous Flight Controllers (For safety), Object Avoidance Systems, and more. With the data collected from these various sensor payloads, Michael Frey will be able to provide high quality data for representatives from the below

- highlighted industries.

 Agriculture: High quality, actionable dat a can be utilized by farmers and their partner agronomists, crop consultants, field techs, and interns alike, to support their drive for higher yields and more efficient and effective farming practices.

 Cinematog raphy: High resolution video can provide a new perspective of a product for potential buyers. By providing an aerial shot to the director of a commercial shoot, these video marketers can more effectively rep resent a compan y’s product, which in turn provide s value to that commercial customer and provides for a stronger economy through increased demand for products and services.

 Environmental Protection: High resolution video and imagery captured from the sky can provide various Environmental groups with more information on their area of study. Near Infrared imagery for example can be used to determine plant stress or de forestation.

 Fire: High resolution imagery captured from the air can help fire departments better assess ongoing fire situations. This could help the department mo re effecively fight an ongoing fire and in some situations help the department decide whether or not to approach a blaze that could present various hazards.

 Insurance: High quality, high resolution imagery, coupled with advanced identification and measurement software, can help turn aerial data collected by a sUAS into actionable information for Insurance Agents and Adjusters alike. With an aerial map of a field for example, advanced software can identify destroyed areas of the field, measure the acres lost, and in turn provide an accurate, automated, non

- partisan assessment of crop loss.

 Land Inspection: High quality, high resolution imagery and 3D modeling can help land assessors, government agencies, surveyors, insurers, and the like utilize aerial data to ensure confidence in their operations and efficiency in their practic es.

 Real Estate: High quality, high resolution imagery and aerial cinematography can provide a new perspective for an interested home buyer which in turn allows for another marketing piece for land developers and real estate agents to move properties and thus create a stronger housing market.

 Search and Rescue: High quality, h igh resolution imagery and aerial video can provide an incredible vantage point from which search and rescue teams can more effectively scope out an area.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 4

The applications highlighted in this petition obviously p rovide high qual ity data to a variety of interested parties in vari ous industries. However, sUAS have more to provide than just interesting pictures and efficient operations. There is also the enhanced safety sUAS provide not only for the operators of these systems, but also, the people around them, communities as a whole, and the National Airspace System (“NAS”).

Within this Petition for Exemption you will find that the applications highlighted above along with the aircraft systems utilized by Michael Frey , satisfy the conditions highlighted by the Federal Aviation Administration as requirements for a successful Section 333 Exemption Petition

. 3 Specifically, the sUAS operating in furtherance of the industry applications above should;

1. Provide a benefit to the public as a whole, and;
2. Not adversely affect safety.

To answer these requirements this Petition for Exemption will highlight the public benefits provided by the proposed sUAS operations as well as sho w the positive affect these operations will have on safety. Specifically, it will be shown that the commercial sUAS flights proposed in this Petition further the public interest by satisfying what is sometimes referred to as the 3D’s or 4D’s of Unmanned A erial Vehicle (“UAV”) Intervention

. 4 Basically, the “D” list provides a description of situations in which an unmanned vehicle should be used in place of a manned aircraft, more clearly, those situations in which an aerial operation is going to be; Dull, Dirty, Dangerous, or Deep

. 5 This list is often associated with early military applications utilizing UAV’s. The UK Ministry o f Defense for example has used this list in determining the rol e of Unmanned Aircraft, highlighting the importance of Unmanned Systems in times where the operation is ; 5

 Dull

- flights require persistence or repetition.  Dangerous

- flights carry a high degree of risk.  Dirty

- flights m ust be carri ed out in hazardous environments, or;  Deep

- flights are beyond the range of tactical

- aircraft, manned platforms.

In addition to the justification that will be provided in detail in the pages to come relating to the 4 D’s of
UAV Interven tion and safety attributes of the sUAS Operations proposed in this Petition for Exemption, it is also important to quickly consider the aircraft types utilized by Michael Frey

.

As mentioned above, Michael Frey seeks exemption for the utilization of the DJI Phantom 3 Professional

, DJI Inspire 1

, DJI Matrice 100

, Immersion Vortex 250 Pro

, and TILT Pro

. All of these air craft ar e small Unmanned Aircraft Systems and are battery

- powered. Operations conducted by Michael Frey with these sUAS will adhere to the guidelines set forth by the Federal Aviation Administration and Community

- Based Organ izations such as the Academy of Model Aeronautics (“AMA”). Through the adherence of these guidelines Michael Frey will c ommercially operate his sUAS with an equivalent level of safety, if not superior level of safety, as out lined by the Federal Aviation Administration’s Section 333 Exemption Guidelines.

Furthermore, the commercial sUAS operations being proposed by Michael Frey in this Petition for Exemption would produce far safer methods of data capture than currently

- used collection methods in which manned aircraft are used. Consider that manned aircraft weigh thousands of pounds, are made of metal, are powered by a combus tion engine, carry flammable fuel, and are carrying people. Plus,
wi th the type of data

- capture proposed in this Petition, a manned aircraft would have to operate inPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 5

high

- risk situations, including, in close proximity to the ground where the risk of an accident is highest and the risk to people an d property on the ground i s greatest. Contrasting the two aircraft types, it is clear that a plastic, battery

- powered, unmanned vehicle operating at low altitudes, would be much safer than a multi

- thousand

- pound metal aircraft, powered by a combustion engine, and carrying a person at low altitudes.

This fact is furt her bolstered by the operational and aircraft

- specific parameters giv en by the FAA when deciding whether or not to grant Section 333 Exemptions

. 6 These directives include ;

1. The size o f the aircraft
2. The weight of the aircraft
3. The speed of the aircraft
4. The operational capability of the aircraft
5. The aircraft operation’s proximity to airports
6. The aircraft operation’s proximity to populated areas , and;
7. The aircraft operation’s adherence to Visual Line of Sight Rules

As highlighted above, it is clear that this Petition for Exemption and both the aircraft types and applications state d herein, strictly adhere to the operational and aircraft

- specific parameters highlighted by the FAA for a succ essful Exemption Petition and thus, support the granting of this Exemption. A summary of the reasoning behind this statement can be found below as;

1. All proposed sUAS are Small
2. All proposed sUAS weigh below 55 lbs.
3. All proposed sUAS travel at less than 10 0 mph (87 Knots)
4. All proposed sUAS are capable flight systems and have been granted Exemptions previously
5. All proposed operations will take place at least 5 miles from an Airport
6. All proposed operations will take place in unpopulated area s (U nless prior ap proval is given {See Condition #34 [“ Proposed Conditions of the Exemption ”] below})
7. All proposed operations will adhere to the Visual Line of Sight Rules

By adhering to t he parameters published by the FAA and by promoting the public good through the various Industry applications to be highlighted below, this Pe tition for Exemption on behalf of Michael Frey s trongly support s approval

.

We kindly ask for your consideration of this Peti tion for Exemption. Please see the table of contents below for all our documentation and for assistance in reviewing this Petition. Thank you for your efforts in reviewing this document and we look forward to your response. If you have any questions whi le reviewing this document, please do not hesitate to ask. You can contact the Preparer of this document for all questions relating to this petition and they can be reached by email at dmzaerial@gmail.com

. Furth er contact information can be found at th e top of this Petition . Once again thank you for your efforts in reviewing this Petition for Exemption and we look forward to your r eply.

Best Regards,

DMZ Marketing, LLC. (DMZ Aerial)PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 6



## Contact Information

Docume nt Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.com

Petitioner:

Michael Frey 11908 Tilbury Way Bakersfield, California 93312
661

- 808

- 0497 mike@buttonwillow.com



## Disclosure

The Petitioner for this exemption is Michael Frey

, a 5th generation farmer and rancher who grows permanent crops including grapes, almonds and pistachios as well as row crops like potatoes, carrots, cotton and wheat among others. Mr. Frey is al so involved in conservation projects in partnership with Ducks Unlimited and has commercial real estate interests in Kern and San Luis Obispo counties in
California. Michael Frey purchased document preparation services thro ugh Dronefly, Inc. for the purpose of petitioning the FAA to be allowed to fly his s mall Unmanned Aircraft Systems commercially within the United States. Dronefly Inc., contracts DMZ Marketing, LLC. also known as DMZ Aerial, to help formulate these docume nts and work with the customer to help promote safe flying practices and appropriate operations. This is done through questionnaires, phone conversations, document preparation, training module creation, and more. If you have any questions relating to the Petitioner, Dronefly, Inc. or DMZ Marketing, LLC. (“DMZ Aerial”), please do not hesitate to contact us using the contact information provided above.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 7



## Table of Contents

Petition for Exemption

................................ ................................ ................................ ............................ 1

Contact Information

................................ ................................ ................................ ................................ 6

Disclosure

................................ ................................ ................................ ................................ ................ 6
The Applicant

................................ ................................ ................................ ................................ ........ 10

Commi tment to Safety

................................ ................................ ................................ ...................... 10
Experience and Expertise

................................ ................................ ................................ ................... 11

Privacy

................................ ................................ ................................ ................................ ............... 11
Publishable Summary

................................ ................................ ................................ ............................ 12

Petitioner’s Contact Information

................................ ................................ ................................ ........... 13
Proposed sUAS Operations

................................ ................................ ................................ .................... 14
Small Unmanned Aircraft Systems

................................ ................................ ................................ ..... 14

DJI Phantom 3 Professional

................................ ................................ ................................ ............ 14

DJI Inspire 1

................................ ................................ ................................ ................................ ... 15

DJI Matrice 100

................................ ................................ ................................ .............................. 15

Immersion Vortex 250 Pro

................................ ................................ ................................ ............. 16

TILT Pro

................................ ................................ ................................ ................................ ......... 16
Unmanned Flight Crew

................................ ................................ ................................ ...................... 16
Unmanned Flight Conditions

................................ ................................ ................................ .............. 17
Unmanned Flight Operations

................................ ................................ ................................ ............. 18
Aircraft and Equivalent Level of Safety

................................ ................................ ................................ ... 18
National Security

................................ ................................ ................................ ................................ ... 19

Propose d Conditions of the Exemption

................................ ................................ ................................ .. 19
Exemptions Requested & Applicable Conditions/Reasoning

................................ ................................ ... 25
14 C.F.R 21(h): Airworthiness Certificates

................................ ................................ .......................... 25

14 C.F.R. 27: Airworthiness Standards

- Normal Category Rotorcraft

................................ .................. 25
14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

................................ ............... 25
14 C.F.R. 43.11: Dispositions of Records for In spections

................................ ................................ ..... 26
14 C.F.R. 45.11: Making of Products

................................ ................................ ................................ ... 26
14 C.F.R. 45.23(b): Display of Marks; General

................................ ................................ ..................... 26
14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft

................................ ................................ .......... 27

14 C.F.R. 45.29: Size of Marks

................................ ................................ ................................ ............ 27PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 8

14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations

................................ .......... 28
14 C.F.R. 61.23(a) and (c): Medical Certificates

– Requirements and Duration

................................ .... 28
14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

................................ ......... 29
14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command

.......................... 30
14 C.F.R. 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

................................ ................... 31
14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

................................ ................................ ..................... 34
14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual

................................ ................................ ................. 34
14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

................................ ................................ ............... 35
14 C.F.R. 91.103: Preflight Action

................................ ................................ ................................ ....... 35
14 C.F.R. 91.105: Flight Crewmembers at Stations

................................ ................................ ............. 36
14 C.F.R. 91.109: Flight Instruction

................................ ................................ ................................ .... 37
14 C.F.R. 91.113(b): Right

- of

- Way Rules

................................ ................................ ............................. 38

14 C.F.R. 91.119: Minimum Safe Altitudes

................................ ................................ ......................... 38

14 C.F.R. 91. 121: Altimeter Settings

................................ ................................ ................................ ... 39
14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

................................ ...................... 41
14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

................................ ..................... 41
14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use

................................ ..... 42

14 C.F.R. 91.403: General

................................ ................................ ................................ ................... 44
14 C.F.R. 91.405(a): Mainte nance Required

................................ ................................ ....................... 44
14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

................................ .................... 45
14 C.F.R. 409(a)(1) and (2): Inspections

................................ ................................ .............................. 45
14 C.F.R. 91.417(a) and (b): Maintenance Records

................................ ................................ ............. 45

Priva cy

................................ ................................ ................................ ................................ .................. 47
Public Interest and Safety

................................ ................................ ................................ ...................... 47
Agriculture

................................ ................................ ................................ ................................ ..... 48
Cinematography

................................ ................................ ................................ ............................ 51

Environmental Protection

................................ ................................ ................................ .............. 53

Fire

................................ ................................ ................................ ................................ ................ 56

Insurance

................................ ................................ ................................ ................................ ....... 58
Land Inspec tion

................................ ................................ ................................ ............................. 59

Real Estate

................................ ................................ ................................ ................................ ..... 61

Search and Rescue

................................ ................................ ................................ ......................... 63
Regulations Requested for Exemption

................................ ................................ ................................ ... 65PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 9

Appendix 1: Regulations Requested for Exemption

– List

................................ ................................ ... 65

Exhibit List

................................ ................................ ................................ ................................ ............. 65
Exhibit 1: Michael Frey Operations Manual

................................ ................................ ........................ 65

Exhibit 2: Michael Frey Logbook Example

................................ ................................ .......................... 65
Exhibit 3: Michael Frey Visual Observer Training Procedures & Guide

................................ ................ 66
Visual Observer Training Procedures

................................ ................................ .............................. 66
Visual Observer Training Guide

................................ ................................ ................................ ...... 66
Exhibit 4: Michael Frey Pilot In Command Training Guide

................................ ................................ .. 66
Pilot In Command Training Procedures

................................ ................................ .......................... 66
Pilot in Command Training Guide

................................ ................................ ................................ ... 66

Exhibit 5: DJI Phantom 3 Professional

................................ ................................ ................................ 67

Exhibit 6: DJI Phantom 3 Professional User Manual

................................ ................................ ............ 67

Exhibit 7: DJI Phantom 3 Professional Quick Start Guide

................................ ................................ .... 67

Exhibit 8: DJI Phantom 3 Professional Features

................................ ................................ .................. 67
Exhibit 9: DJI Phantom 3 Professional Specifications

................................ ................................ .......... 67
Exhibit 10: DJI Phantom 3 Professional Flight Control ler System

................................ ........................ 67
Exhibit 11: DJI Phantom 3 Professional Smart Battery Manual

................................ ........................... 67
Exhibit 12: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

................. 68
Exhibit 13: DJI Inspire 1

................................ ................................ ................................ ...................... 68
Exhibit 14: DJI Inspire 1 User Manual

................................ ................................ ................................ . 68
Exhibit 15: DJI Inspire 1 Quick Start Guide

................................ ................................ .......................... 68
Exhibit 16: DJI Inspire 1 Features

................................ ................................ ................................ ....... 68

Exhibit 17: DJI Ins pire 1 Specifications

................................ ................................ ................................ 68
Exhibit 18: DJI Inspire 1 Flight Controller System

................................ ................................ ................ 68
Exhibit 19: DJI Inspire 1 Smart Battery Manual

................................ ................................ ................... 68

Exhibit 20: DJI Matrice 100

................................ ................................ ................................ ................ 69

Exhibit 21: DJI Matrice 100 User Manual

................................ ................................ ............................ 69

Exhibit 21: DJI Matrice 100 Features

................................ ................................ ................................ .. 69
Exhibit 22: DJI Matrice 100 Specifications

................................ ................................ .......................... 69

Exhibit 23: DJI Matrice 100 Smart Battery Manual

................................ ................................ ............. 69

Exhibit 24: Immersion Vortex 250 Pro

................................ ................................ ................................ 69

Exhibit 25: Immer sion Vortex 250 Pro User Manual

................................ ................................ ........... 69

Exhibit 26: Immersion Vortex 250 Pro Quick Start Guide

................................ ................................ .... 70PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 10

Exhibit 27: Immersion Vortex 250 Pro Features

................................ ................................ ................. 70
Exhibit 28: Immersion Vortex 250 Pro Specifications

................................ ................................ .......... 70
Exhibit 29: Immersion Vortex 250 Pro Flight Controller System

................................ .......................... 70

Exhibit 30: TILT Pro

................................ ................................ ................................ ............................ 71

Exhibit 31: TILT Pro Features

................................ ................................ ................................ .............. 71
Exhibit 32: TILT Pro Specifications

................................ ................................ ................................ ...... 71
Exhibit 33: TILT Pro Fligh t Controller System

................................ ................................ ...................... 72

References

................................ ................................ ................................ ................................ ............ 7 2
Exemption References

................................ ................................ ................................ ........................... 73



## The Applicant

The Applicant seeking this Exemption is Michael Frey , headquartered at;

11908 Tilbury Way Bakersfield, California 93312

Michael Frey is from a family that has been farming and ranching on the same land in California since 1862, making his farm over 150 year s old. Today, Mr. Frey, along with his partners, farm over 9,000 acres of various crops, including; grapes, almonds, pistacios, potatoes, carrots, cotton, and wheat among others. Additionally, contained within the land Mr. Frey owns are various ponds and other natural features that he leases out for duck hunting and co

- manages conservation efforts with organizations such as Ducks Unlimited. Along with farming, Mr. Frey and his business partners manage various forms of commercial real estate, including; o ffice buildings, retail strip malls, bars, and a hotel. Mr. Frey is actively engaged in both the aquistion and management of these properties.

Between Mr. Frey and his business partners, there are six licensed pilots and two aircraft, making Mr. Frey ver y familiar with aviation. Mr. Frey specifically, has been a pilot since 2001, with ratings for Single Engine Land and Instrument Airplanes. He has logged more than 300 hours and 300 landings throughout his career as a pilot. Furthermore, Mr. Fre y has be en flying multi

- rotor , hobbyist

- drones for more than three years and this experience in combination with his pilot experience provides him with a unique perspective and appreciation for flying safely in the National Air Space. Mr. Frey has a record as

a s afe pilot and will continue to operate safely if he is granted a Section 333 Exemption.



### Commitment to Safety

Mr. Frey is committed to operating safely within the National Airspace System. He has a vested i nterest in the safe operations of UAVs within the NAS due to his own manned flights within the NAS as well as the manned flights of many of his close friends and business partners. Furthermore, as can be seen by Mr. Frey's extensive business experience in various industires, including industries, such as agriculture,PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 11

in which safety is heavily regulated by oversight bodies such as OSHA, the EPA, and the DOT, it is clear Mr. Frey is committed to providing safe operations within his various business interest s. Furthermore, it should be noted that Mr. Frey's current company has quarterly safety meetings that center on the current activities that are happening on the farm at that time, whether they be planting, tilling, pesticide application or harvest operati ons. These types of meetings are vital for continued safe operations and this current safety model is one in which Mr. Frey will use with his Pilots In Command and Visual Observers in order to keep them up to date on UAV saftey. Additionally, Mr. Frey's p ast UAV experience as a hobbyist, flying multi

- rotor drones for more than three years, coupled with his experience as a licensed pilot provides him with a unique perspective and appreciation for flying safely in the National Air Space.



### Experience and Exp ertise

Mr. Frey has extensive manned aviation and sUAS experience. As a pilot, Mr. Frey has logged over 300 hours and 300 landings. Furthermore, he is rated for Single Engine Land and Instrument Aircra ft. This manned aviation experience gives Mr. Frey the knowledge of all applicable FARs relating to the safe operation of aircraft within the National Airspace System. Additionally, Mr. Frey has been a hobbyist sUAS pilot for over three years, operating a variety of aircraft, including the listed aircraft he intends to fly commercially should his petition for exemption be granted.

In addition to Mr. Frey's experience in both manned and unmanned aviation, he also has extensive knowledge in various industri es. As has been highlighted, Mr. Frey is from a family that has been farming and ranching on the same land in California since 1862, making his operation over 150 years old. Mr. Frey, along with his partners, farm more than 9,000 acres of various permanen t and row crops. Plus, in undeveloped areas, Mr. Frey leases out his land for duck hunting and conservation efforts. Furthermore, Mr. Frey has extensive experience in commercial real estate, actively overseeing the acquisition and managing of multiple co mmercial properties, including; office buildings, retail strip malls, bars, and a hotel.

Finally, between Mr. Frey and his business partners, there are 6 licensed pilots and 2 aircraft, making both Mr. Frey and his team very familiar with aviation. This aviation knowledge coupled with Mr. Frey's experience in multiple industries provides him with a unique perspective and appreciation for flying safely in the National Air Space.



### Privacy

Privacy is important in any business, but es pecially one in which imagery is captured. For this reason, Mr. Frey will use commonly accepted practices in order to secure his imagery. A few of the practices he will put into action include; obtaining proper permissions, notifying authorities of any p ending flights that may cause call

- ins, keeping data on a secure computer system, and the like. Furthermore, he will also seek what is required by law to remain compliant and secure in terms of data/imagery privacy.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 12

Specifically, he will ask permission b efore filming identifiable non

- participants during his commercial UAV flights. He will also keep the data secure for his clients, provide them access to their data for a

contract

- agreed

- upon period of time, and destroy or return their data at their reques t.



## Publishable Summary

DMZ Marketing, LLC. files this petition for exemption on behalf of Michael Frey

, a 5th generation farmer
and rancher who grows permanent crops including grapes, almonds and pistachios as well as row crops like potatoes, carrots, cotton and wheat among others. Mr. Frey is also involved in conservation projects in partnership with Ducks Unlimited and has commercial real estat e interests in Kern and San Luis Obispo counties in California. Michael Frey is seeking exemption from certain parameters of 14 C.F.R. in
orde r to commercially operate sUAS within the United States in the following industri es; Agriculture

, Cinematography

, Environmental Protection

, Fire

, Insurance

, Land Inspection

, Real Estate

, and Search
and Rescue

. Specifically, Michael Frey requests exemption from the following Federal Aviation Administration rules;

1. 14 C.F.R 21(h): Airworthiness Certificates

2. 14 C.F.R. 27: Airworth iness Standards

- Normal Category Rotorcraft
3. 14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

4. 14 C.F.R. 43.11: Dispositions of Records for Inspections

5. 14 C.F.R. 45.11: Making of Products

6. 14 C.F.R. 45.23(b): Display of Marks; General

7. 14 C. F.R. 45.27: Marking of the Aircraft

– Rotorcraft
8. 14 C.F.R. 45.29: Size of Marks
9. 14 CFR 61.3: Requirement for Certificates, Ratings, and Authorizations

10. 14 CFR §§ 61.23(a) and (c): Medical Certificates

– Requirements and Duration

11. 14 CFR 61.101(e) (4) and (5) : Recreational Pilot Privileges and Limitations
12. 14 CFR 61.113(a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command
13. 14 C.F.R. 61.315(a): Privileges and Limits of Sport Pilot’s License

14. 14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

15. 14 C.F.R . 91.9(b)(2): Civil Aircraft Flight Manual
16. 14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

17. 14 C.F.R. 91.103: Preflight Action

18. 14 C.F.R. 91.105: Flight Crewmembers at Stations
19. 14 C.F.R. 91.109: Flight Instruction
20. 14 C.F.R. 91.113(b): Right

- of

- Way Rules
21. 14 C.F.R. 91.119: Minimum Safe Altitudes

22. 14 C.F.R. 91.121: Altimeter Settings
23. 14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

24. 14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required
25. 14 C.F.R. 215: ATC Transponder and Altit ude Reporting Equipment and Use

26. 14 C.F.R. 91.403: GeneralPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 13

27. 14 C.F.R. 91.405(a): Maintenance Required
28. 14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

29. 14 C.F.R. 409(a)(1) and (2): Inspections
30. 14 C.F.R. 91.417(a) and (b): Maintenance Records

The approval of this Petition for Exemption would allow for the commercial operation of small Unmanned Aircraft Systems by Michael Frey

. These commercial operations would strictly adhere to all
Federal Aviation Administratio n rules and regulations not stated herein as rules requested for exemption. The commercial operations flown by Michael Frey , if this Petition were granted, would be flown utilizing one of the following aircraft platforms; th e DJI Phantom 3 Professional

, DJI Inspire 1

, DJI
Matrice 100

, Immersion Vortex 250 Pro

, and TILT Pro

. Specifically, the commercial operations utilizing

t hese unmanned aircraft wo uld center around the following industry applications; Agriculture

, Cinematography

, Environmental Protection

, Fire

, Insurance

, Land Inspection

, Real Estate

, and Search
and Rescue

. Additionally, all the industry applications highlighted above would include one or more of the unmanned
aircraft noted above flying no more than 400 feet Above Ground Level (“AGL”) o r in airspace otherwise

spec ified in a granted Certificate of Authorization (“COA”).

Furthermore, this Petition for Exemption should be granted to Michael Frey because th e operation of th e listed sUAS above will provide for commercial operations while maintaining an equivalent level of safety as would be provided by the above

- listed rules. Additionally, as will be highlighted below, the small Unmanned Aircraft utilized by Michael Frey will provide methods of aerial data collection far safer than
the alternative of manned aircraft collection of the same data sets. Low altitude data

- collection flights, in close proximity to people and property, are far safer w hen accomplished using a battery

- pow ered sUAS weighing less than 10 lbs., than with a combustion

- engine

- powered, multi

- thousand

- pound, manned

aircraft, with flammable fuel onboard.

Considering the seve n factors highlighted by the FAA as parameters for s uccessful Section 333 Exemption Petitions, including; Size, Weight, Speed, Operational Capability, Proximity to Airports, Proximity to Populated Areas, and Operations within Visual Line of Sight

, 6 this Petition supports the Petitioner’s

re quest for exemption relating to each operational and aircraft

- specific parameter . Specifically, the aircraft utilized by Michael Frey are in the small

- size category as they are below the 55 lbs. weight class, they travel at less than 100 mph, they are proven flight platforms based on previously granted petitions, all operations will be conducted at least 5 miles from an airport and over unpopulated areas (unless otherwise granted permis sion by the FAA in a gra nted Certificate of Authorizatio n), and all flights will be
conducted within Visual Line of Sight.

In addition, the data collectio n flights provided by the sUAS highlighted in this Petition will promote safer operations for professional service providers in the aforementioned industries.



## Petitioner’s Contact Information

Petitioner:

Michael FreyPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 14

11908 Tilbury Way Bakersfield, California 93312
661

- 808

- 0497 mike@buttonwillow.com



## Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.com



## Pr oposed sUAS Operations

Small Unmanned Aircraft Systems

This Petition for Exemption under Section 333 will permit the Petitioner to operate the DJI Phantom 3
Professional

, DJI Inspire 1

, DJI Matrice 100

, Immersion Vortex 250 Pro

, and TILT Pro

. Further operating characteristics, specifications, and other important craft

- specific information on the DJI Phantom 3
Professional

, DJI Inspire 1

, DJI Matrice 100

, Immersion Vortex 250 Pro

, and TILT Pro are covered in detail starting with Exhibit 5 . Each of these documents are publically circulated and have been previousl y vetted by the FAA in previously granted Petitions for Exemption under Sect ion 333. In the aircraft
summaries below , please see the references to previously granted petitions for the use of each specific aircraft type in commercial operations within the United States

.


### DJI Phantom 3 Professional

The requested exemption will permit the Petitioner the right to use the DJI Phantom 3 Professional Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phantom 3 Professional has a weight of 1280 grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight speed
of 16 m eters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral directionPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 15

For easy reviewing, please see the Phantom 3 Pro fessional

- Specific Exhibits below for more information on the DJI Phantom 3 Professional craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these suppor ting documents for the commercial use of the DJI Phantom 3 Professional in the following listed Exemption;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587A



### DJI Inspire 1

The requested exemption will permit the Petitioner the right to use the DJI Inspire 1 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issue d COA’s, and the like. The DJI Inspire 1 has a weight of 2935 grams including the battery payload. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Inspire

- Specific Exhibits below for more information on the DJI Inspire 1 craft, its specifications , abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Inspire 1 in the following listed Exemptions;

 Jeffery Greer

– Ber kshire Hathaway Home Services

– Exemption Number 11587/11587A  Phillip Stiles

– GPS Development, LLC dba SkyViewHD

– Exemption Number 11399/11399A



### DJI Matrice 100

The requested exemption will permit the Petitioner the right to use the DJI Matrice 100 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Matric e 100 has a maximum take

- off weight of 3400 grams including technical payloads and batteries. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral directionPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 16

For easy reviewing, please see Matrice 100

- Specific Exhibits below for more information on the DJI Matrice 100 craft, its specifications, ab ilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Matrice 100 in the following listed Exemption;

 Dan Pham

– Alert5 Inte rnational, LLC.

– Exemption Number 11814



### Immersion Vortex 250 Pro

The requested exemption will permit the Petitioner the right to use the Immersion Vortex 250 Pro Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The Immersion Vortex 250 Pro has a take

- off weight of 415 grams without the battery (the unit will obv iously neve r exceed the 55 lbs. limit as its max take

- off weight will be well below 55 pounds). Furthermore, this quadcopter flies at speeds that will not exceed the 100 mph airspeed maximum as set by the FAA and has the following abilities;

 Vertical Tak e

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Immersion Vortex 250 Pro

- Specific Exhibits below for more information
on the Imm ersion Vortex 250 Pro craft, its specifications, abilities, and more.



### TILT Pro

The requested exemption will permit the Petitioner the right to use the TILT P ro Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The TILT Pro has a take

- off weight of 800 grams. Furthermore, this quadcopter is capable of a max fligh t speed of 110 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see t he TILT Pro

- Specific Exhibits below for more information on the TILT Pro craft, its specifications, abilities, and more.



### Unmanned Flight CrewPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 17

The unmanned flight crew ope rating Michael Frey fl ight crafts for purposes of commercial operations within the United States under this proposed Exe mption will consist of a Pilot I n Command (“PIC”) and a Visual Observer (“VO”).

Adhering to current FAA guidelines and precedent established in previously g ranted Section 333 Exemptions, the PIC will have, at minimum, a Recreational or Sport Pilot’s License and a Third Class
Medical Certificate or a valid U.S. Driver’s License

. 7 Additionally, both the PIC and VO will be train ed in the operation of sUAS prior to commercial operations. Furthermore, any new information surrounding the aircraft’s efficient, effective, or safe operations, will be disseminated by Michael Frey to both the PIC
and VO to ensure continued safe flights.

On top of the general sUAS training, the PIC will also have completed, at a minimum, 25 hours of sUAS flight training with the specific sUAS craft they are using for their commercial operation and will be required to receive annual continued educatio n and training moving forward. A specific PIC Training Presentation is contained in the exhibits below and will accompany this Petition for Exemption.

The Visual Observer will also have completed specific trai ning relating to the ir duties during an unmanned flight. The training procedures that will be used to educate VO’s are contained in Exhibits 1
& 3 below.



### Unmanned Flight Conditions

As has been described above, the sUAS use proposed by the Petitioner in this Petition for Exemption
under Section 333 revolves around the following industries; Agriculture

, Cinematography

, Environmental Protection

, Fire

, Insurance

, Land Inspection

, Real Estate

, and Search and Rescue

. Each of these industry applications will be described in further detail below under the “ Unmanned Flight Operations ” Title.

Moving on from the specific use cases, it should also be noted that all commercial sUAS flights proposed in this Petition for Exemption will be conducted below 400 feet AGL or as otherwise permitted in a granted Cert ificate of Authorization. Furthermore, all flights will be conducted within Visual Line of Sight, as is currently advised by the Federal Aviation Administration and Academy of Model
Aeronautics

. 6 Additionally, the PIC wil l only operate the Petitioner’s sUAS if weather conditions permit safe operations. The judgement of “Safe Weather Conditions” will be determined based on several standing classifications developed by the Federal Aviation Administration. These include ope rations being conducted under the Visual Meteorological Conditions (“VMC”) rules.

As stated previously in this Petition, Michael Frey will strictly adhere to the FAA’s V isual F light R ule s, an d obviously, to be following Vis ual Flight Rules, Michael Frey will have to first satisfy the Visual Meteorological Conditions associated with VFR flights. In particular, the Petitioner will be cognizant of the boundary between Visual Meteorological Condit ions, which allow for Visual Flight Rules, and Instrument Meteorological Conditions, which require Instrument use. Specifically, Michael Frey will be considering the VMC Minima pertaining to Visibility, Cloud Ceilings, and C loud Clearances associated with airspace below 400 feet AGL, where the Petitioner’s sUAS will be flying. Thus, the Petitioner willPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 18

only operate when visibility is at least 3 statute miles from the PIC and at a minimum of 500 feet below and 2,000 feet hori zontally from a cloud

. 8

In addition to the particular flight conditions stated above, it should also be noted that the flight crew will always make an assessment of the current situation for each, specific flight. This ass essment will conclude with a determination of the relative safety of the flight and any risks or hazards that may be present. If this assessment finds that the flight will be too dangerous or that there are too many hazards
or risks associated with the fl ight, the flight crew will not take off. Furthermore, in order to maintain the safety of the general public, flight operations utilizing the Petitioner’s sUAS will only take place after permission is granted to the Petitioner by the landowner, property ow ner, or other controlling representative. All current FAA regulations not covered within this petition will be followed as well as all local and state rules surrounding flights near or around people. Additional information on the parameters dictating fli ghts near people can be found below in the “ Proposed Conditions of the Exemption .”



### Unmanned Flight Operations

When conducting commercial flight operations under the pro posed applications in this Petition for

Exe mption , a commitment to safety will always be paramount. Additionally, with the goal of each flight to accurately collect valuable aerial data in an efficient manner, it will be vital for all flights to be safe for several reasons, including;

 The safety o f the Michael Frey Flight Crew will be necessary for continued flights.  The safety of the general public will be necessary for continued operations.  The safety of the aircraft will be necessary for continued commercial endeav ors.

Furthermore, in an effort to supply the Agriculture

, Cinematography

, Environmental Protection

, Fire

, Insurance

, Land Inspection

, Real Estate

, and Search and Rescue industries with valuable data, it will be imperative for all Michael Frey flights to be conducted in a safe and professional mann er so as to not risk the safety of the flight crew, general public, or aircraft as well as to avoid damaging people or property operating in the National Airspace System or on the ground below.

To ensure the safe and professional execution of each sUAS f light, all flights will be conducted utilizing at
least a two

- person flight crew. This flight crew will consist of an adequately

- trained (“ Unmanned Flight
Crew ” ) PIC and VO. For specifics pertaining to the standar d operating procedures utilized by the Petitioner under the proposed Petition for Exemption and for more details on training, please see
Exhibits 1

- 4

. 

## Aircraft and Equivalent Level of Safety

As is stated in the FAA’s Se ction 333 Exemption Guidelines, Petitioners for Exemption must show that their proposed commercial, sUAS operations provide a level of safety at least equal to that provided by the rule from which the Petitioner seeks an exemption

. 6 As will be highlighted below, the request forPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 19

this Exemption by th e Petitioner is fortified by his commitment to safety. Furthermore, the operation of sUAS by the Petitioner, using the previously stated flight crafts and operating within the ab ove

- stated

use

- cases under the rules, regulations, and limitations stated herein, should be permitted under the proposed exemption. Reasoning for this can be derived from the strict adherence to existing regulations
from the Federal Aviation Administratio n as well as the adoption of the following conditions ; each providing at least an equivalent level of safety as is provided by the existing rule.



## National Security

In addition to the arguments supporting the Petitioner’s exemp tion from certain rules contained in 14
C.F.R. , it is also important to note that the granting of this petition and in turn, permission for the
Petitioner to conduct commercia l sUAS flights, will not present a national security threat . As has been stated in this Petition

, and

, as is precedent from the F ederal Aviation Administration , the PIC of a sUAS must hold, at minimum, a Recreational or Sport Pilot’s Certificate, meaning he or she has already been subject to a security screening by the Department of Homeland Security. 9

This provision, relating to the acquisition of a Recreational or Sport Pilot’s Certificate, points to checks already provided by the FAA and Department of Homeland Security in ens uring secure aircraft operations. As is stated by the Aviation and Transportation Security Act, the Transportation Security Administration (“TSA”) must assess information in order to identify individuals that may pose a threat to transportation security a nd coordinate countermeasures with other Federal Agencies such as the FAA. Therefore, due to the fact it is a requirement for all PICs to be at least Recreational or Sport Pilot Certified, it can be assumed that adequate security checks by the TSA and FAA have taken place prior to a sUAS Pilot conducting commercial operations.


## Proposed Conditions of the Exemption

As is noted by the Federal Aviation Administration in their, “Section 333 Petition Guidance & Checklist” 3
f orm, Section 333 Exemption Petitioners are strongly advised to, “Carefully review the Conditions and
Limitations Section in the most recently granted exemptions.” 3 Due to this, the following Conditions of the proposed Exem ption closely follow this guidance and mirror many of the same conditions previously noted by other exemption petitioners. The following list will highlight these conditions and establish a framework from which the petitioner, Michael Frey , will conduct his commercial sUAS operations under a granted petition for exemption.

1. Proposed operations using Small Unmanned Aircraft Systems in the United States under the granted form of this Petition for Exemption will be limited to the following aircraft, which all weigh less than 55 pounds including batteries and operational/technical payloads; DJI Phantom
3 Professional

, DJI Inspire 1

, DJI Matrice 100

, Immersion Vortex 250 Pro

, and TILT Pro

. Furthermore, any aircraft outside of this comprehensive list for this Petition for Exemption will have to be added to an amended version of this petition or a new Petition for Exemption must be filed with the new fligh t platform (s)

.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 2 0

2. The proposed use

- cases/applications contained within this Petition for Exemption under Section 333 are as follows; Agriculture

, Cinematography

, Environmental Protection

, Fire

, Insurance

, Land Inspection

, Real Estate

, and Search and Rescue

. All of these flights will take place below 400 feet AGL nationwide unless otherwise advised in an
ATO

- issued Certificate of Waiver or Authorization.

3. All flights conducted by Michael Frey will be below 400 feet AGL, operated within Visual Line of Sight, and have a live, GPS

- based, read

- out of altit ude during the flight. Furthermore, each flight will begin with a “Zero Altitude” start point, thus creating an accurate AGL calculation.

4. All flights conducted by the Petitioner will be controlled by a trained flight crew consisting of a licensed (at minimum Recreational or Sport Pilot’s Certificate) PIC with a Medical Certificate or equivalent valid U.S.A. Driver’s license and a trained Visual Observer.

5. All flights conducted by the Petitioner will include aircraft that are flying below the 87 knot ( 100 mph) airspeed maximum, highlighted by the FAA in their guidelines.

6. All flights conducted by Michael Frey will be conducted within Visual Line of Sight, during daytime flying hours, and adhere to Visual Flight Rules und er the Visual Meteorological Conditions associated with 400 foot AGL airspace.

7. The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the qualification standards set by the Federal Aviation Administration (i.e. Minimum

- Sport Pilot ’s Certificate and Medical or U.S.A. Driver’s License) and by the safety guidelines and operational capabilities relating to safe sUAS operations, such as;

a. Evasive Maneuvers
b. Emergency Actions

c. Fail

- Safe Knowledge
d. Flight Skills
i. Maintaining adequate distance s from;

1. People
2. Property
3. Structures
4. Etc.

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R. 61.51(b). Additionally, a record of the PIC training will be documented and made available upon request by the Administrator.

9. Tra ining operations will only be conducted during dedicated training sessions. During training, all persons not essential for flight operations will be deemed nonparticipants, and thus, the PIC will operate the aircraft with appropriate distance from nonparti cipants in accordance with 14
C.F.R. 91.119.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 21

10. As highlighted by the FAA, the Visual Observer’s duty is to visually observe the relevant airspace for aircraft, hazards, obstacles, structures, or the like. For this reason, the VO will not be allowed to ope rate the camera or other instruments on the sUAS during flight operations. Instead, a third person will have to serve as a camera operator if the flight crew seeks a dedicated pilot and dedicated camera operator.

11. The PIC, for the duration of an unmann ed flight, will be named prior to the flight. Due to this, once the PIC is named and a flight is begun, the PIC will not be able to transfer his/her designation as the PIC through the duration of the flight. Furthermore, the PIC is the Captain of the fli ght crew and will ensure that the Visual Observer is qualified to hold the VO position for the duration of the flight.

12. Each commercial sUAS flight performed by Michael Frey will be planned for ahead of the flight date. Th is will be to ensure adequate time for all participants to prepare and to obtain all the necessary permissions (landowners, homeowners, property owners, etc.) if any are needed. All flights will be preceded by a meeting at least one day before the flight at which all participants of the flight will be present. This is to ensure adequate knowledge and preparedness prior to the sUAS flight.

13. Aircraft maintenance is obviously vital for any commercial sUAS operation. It ensures safety and is necessary prio r to each flight to maintain safe, efficient, and effective flight operations. Once again, the PIC, as the captain of the flight crew, will take a leading role in inspecting the aircraft prior to flight. The PIC will likely have the most experience of an yone on the flight crew and will be in tune with the specific maintenance needs of each specific flight craft. If the PIC were to find an error in the flight craft or any of the associated systems, including the Ground Control System for example, he/she w ould ground the flight until adequate maintenance is completed and the aircraft is once again safe to fly. All maintenance on flight crafts utilized by the Petitioner will be noted and logged to ensure the safety of all aircraft and the people operating

t hem.

14. Relating to the above Condition, anytime a flight

- critical component is replaced or anytime there is mission

- critical maintenance on the craft, the PIC will conduct a flight test of the system before completing the intended, commercial mission. On ce again this flight test will be logged by the PIC.

15. Routine maintena nce and inspections of the sUAS will be logged by the PIC in accordance with the requirements and suggestions laid out by the aircraft manufacturer in terms of aircraft component mainte nance, overhaul, replacement, inspection, and life limits, which are part of the supporting documents for each aircraft below in the aircraft

- specific exhibits . The logging of these maintenance/inspection checks will be included in the aircraft records an d include the total time of service and description of work.

16. All sUAS flights will be conducted within Visual Line of Sight (“VLOS”) of both the PIC and VO at all times. Furthermore, VLOS means visual observance unaided by any device other than

correct ive lenses such as eye glasses or contacts. The use of telescopes, FPV systems (for purposes of VLOS flights), binoculars, and the like will not be permitted. Also, both the PIC and VO should be in constant, verbal communication range. The use of other devices toPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 22

communicate out of verbal range are not permitted. These devices would include, cell phones, text messaging, walky

- talkies, and the like.

17. No commercial flight missions will be executed unless it can be determined that the flight crew

can com plete their mission from take

- off through landing, with a reserve of 25% battery life. The Petitioner’s newest flight crafts have adaptive battery monitors and

, for this reason

, this condition will be an automated process as the Petitioner can set the def ault Advisory and Critical Battery warnings to 35% and 30% respectively, which will warn the PIC of the depleted battery and engage him/her to fly home and land with 25% remaining power. For all Michael Frey systems without this automated feature, a watch will be used to monitor flight times to ensure a safe return home with adequate battery power. However, due to the revolving adoption of the newest flight platforms and the current stock of new generation flight crafts, the overwhelming majority of sUAS flights after the granting of this exemption will utilize a Smart Battery System.

18. In the case of an unexpected obstacle or in

- flight issue, each sUAS the Petitioner operates will have the ability to abort a mission and take corrective actions.

19. The sUAS utilized by Michael Frey will be programmed so that if the sUAS loses signal with the PIC or Ground Control Station during flight, the system will return to a preprogrammed GPS location locat ed within the operating area containing the flight crew. Furthermore, this failsafe can also be used in controlled situations, mean ing the failsafe can be engaged should something happen on the ground that disallows the PIC from bringing the sUAS back in a normal fashion. Additionally, in both situations described above, where the failsafe is either a controlled action from the pilot or an uncontrolled situation, like radio

- link signal loss, the unit will not only fly back to its preprogrammed home point, it also has the ability to land itself. This allows safe operations of the aircraft even in troublesome situations, such as signal loss, and prevents the unit from flying off uncontrollably or landing in an unknown location.

20. The operating documents req uired under 14 C.F.R. 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the aircraft anytime the sUAS is operating. Furthermore, these documents will be available for review by the Administrator or other law enfo rcement officials upon request and are additionally contained in Exhibit 1, with appropriate links to the specific flight manuals of each flight craft requested in this Petition for Exemption.

21. It is always important to specify precedent when determinin g operating practices. For this reason, if a discrepancy exists between the conditions laid out in this Petition for Exemption and the actual Granted Exemption, the conditions laid out in the finalized Granted Exemption will take precedent over the condit ions laid out in this Petition. Furthermore, if there are no discrepancies between the Petition and Grant of Exemption, the Petitioner will follow the procedures outlined in the Operating Documentation below. Additionally, if any changes are made to the Operating Procedures and Documentation contained in this Petition for Exemption, the Petitioner will present the updated documents upon request from the Administrator. Also, should the Petitioner determine that an update or change to the procedures or doc umentation would affect the basis of the approved version of this Petition for Exemption, the Petitioner will either file for an amendment to the existing Exemption or create a new Petition with the
revisions.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 23

22. As has been noted, the Petitioner will obt ain written and/or oral permission from the landowners, farmers, property owners, or otherwise authorized agents for flights above their property.

23. The Petitioner will also obtain all required permissions and permits from territorial, state, county or cit y jurisdictions, including;

a. Law Enforcement b. Fire Departments

c. Municipal Agencies, or; d. Other Appropriate Governmental Bodies

24. The Petitioner will not conduct operations at night. Furthermore, all operations will be conducted under Visual Meteorological Con ditions (“VMC”).

25. The Petitioner is aware of the need to obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting operations under the grant of exemption. The Petitioner intends to fly under the Blanket COA provided by the FAA in March of 2015 for flights below 200 feet to all Section 333 Exemption holders or under a future ATO

issued COA that will be applied for by the Petitioner after receiving their Section 333 Exemption.

26. All sUAS flights co nducted by the Petitioner will be done so in accordance with airspace requirements established by the FAA and/or an ATO

- issued COA, including;

a. Class of Airspace b. Altitude Level, and potential;

c. Transponder Requirements

27. As has been stated, the sUAS will not be operated within 5 nautical miles of an airport reference point as noted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s Air Traffic Control is obtained, and the operation is conducted in accordance with

a NOTAM as required by the Operator’s COA.

28. As stated previously, the Petitioner will follow VMC guidelines for VFR flights and as such, will fly only when there is visibility equal to, or in excess of, 3 statute miles from the PIC, while maintaining an ad equate distance of no less than 500 feet below, or less than 2,000 feet horizontally from a cloud.

29. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide or as otherwise advised in an ATO

- issued COA.

30. All sUAS craft flown by t he Petitioner will be marked and identifiable by a serial number which will be as large as practicable given the relatively small size of the aircraft. The FAA has previously stated that so long as the markings are as large as practicable given the size o f a sUAS, an equivalent level of safety can be achieved.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 24

31. All aircraft utilized by the Petitioner operate via radio frequency, which is governed by the Federal Communications Commission (“FCC”). For this reason, prior to commercial operations
under a granted Section 333 Exemption, the Petitioner will ensure the radio frequency spectrum used to operate and control its sUAS complies with FCC or other appropriate government oversight agency rules and regulations.

32. As is stated in the FAA guidelines, a s UAS is required to yield the right of way to all manned aircraft and aviation operations at all times. This rule will be strictly followed by the Petitioner.

33. The concentration of a PIC is necessary for safe operations. It is for this reason that the
Pe titioner will not allow any sUAS operations while a PIC is in a moving device or vehicle. These vehicles would include things like;

a. Cars/Trucks/SUVs b. Boats

c. Tractors d. ATVs

34. All sUAS operations by the Petitioner will be conducted at least 500 feet from all

n onparticipating people, vessels, vehicles, and structures, unless the following conditions apply;

a. Protective barriers are present that adequately protect nonparticipants from flying shrapnel or debris should there be an accident. Furthermore, should a no nparticipant leave this safe

- zone, the PIC will end the flight.

b. The Petitioner has been granted permission to operate near a vessel, vehicle, or structure by the owner/controller of these properties. In addition to permission, the PIC will also have to perform a risk assessment of the situation and potential obstacles/flight hazards and determine the safety of the flight. If it is determined that the hazards present no risk, the PIC can start the mission.

35. The Petitioner will log and report to the UA S Integration Office within 24 hours of any incident, accident, or flight operation that occurred outside the horizontal and vertical boundaries of the operational area as defined by the COA under which the flight was operating. Furthermore, the
Petitione r will report accidents to the National Transportation Safety Board (NTSB).

36. The Petitioner will provide additional flight training to PICs that may be towing objects in the event of an exemption from 14 C.F.R. 61.315 (c) (18). In the event that the Petit ioner is exempt, each PIC that is designated as being a potential candidate for flying a sUAS while towing an object will be required to undergo additional training, on top of their required training and certifications, that will consist of 10 hours of tra ining flights while towing objects. These objects will be dummy banners that weigh no more than the max weight allowable to satisfy the max takeoff weight specifications as highlighted by the manufacturer for each flight craft. Furthermore, the 10 hours o f training will be required for each aircraft type, thus giving the PIC adequate training time and experience while towing objects with specific flight crafts. This will be necessary to familiarize each PIC with each specific flight craft in order to lear n how specific flight craft respond to towing objects, particularly with regard to downwash and wind.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 25

Additionally, of the 10 total flight hours required for training on towing objects, 5 of these hours must be in the max wind tolerances as specified by t he manufacturer for each flight craft. Training in these conditions will hone the skills of each PIC and allow them to operate in the worst case scenario for towing objects, which is high wind. When conducting actual commercial flights while towing objec ts, the Petitioner will not conduct flights in conditions where sustained winds are more than 75% of the maximum wind tolerance of the aircraft or when there are wind gusts in excess of 75% of the maximum wind tolerance as specified by the manufacturer for each aircraft.



## Exemptions Requested & Applicable Conditions/Reasoning

14 C.F.R 21(h) : Airworthiness Certificates

Subpart (h) of Part 21 from the Code of Federal Regulations Title 14, Chapter 1, prescribes procedural requirements for the issuanc e of Airworthiness Certificates. Proposed Conditions 1, 2, 3, 4, 5, 15, 24, 27, 28, and 33 are all applicable to this particular Regulation and the FAA has found in favor of exempting previous Petitions #11062, 11063, 11064, 11065, 11066, and 11067 for th is portion of 14 C.F.R. Furthermore, it is the belief of the Petitioner that a sUAS operating without an Airworthiness Certificate but within the conditions stated above would provide an equivalent level of safety to an aircraft operating with an airworth iness certificate not subject to the above conditions or limitations.

Additionally, all the sUAS proposed within this Petition for Exemptio n are small, weigh less than 10 lbs

. , have a flight speed of less than 100 mph, carry no pilots or passengers, carry no flammable fuel, are
electric

- powered, are operated below 400 feet, are operated at least 5 miles from an airport, and are flown within unaided, visual line of sight of a trained and licensed Pilot In Command. Plus, with built

- in
fail

- safes that include GPS Guidance technologies, Return to Home Features for lost signal and low battery emergencies, and for the ability to regain radio connection with the craft after a fail

- safe is engaged, it is clear the proposed aircraft have safety features equivalent t o and superior to conventional aircraft that hold airworthiness certificates. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 21(h).



### 14 C.F.R. 27 : Airworthiness Standards

- Normal Category Rotorcraft

Title 14, Pa rt 27 of the Code of Federal Regulations creates the procedural requirements for airworthiness certification of Normal Category Rotorcraft. Due to the fact that the proposed aircraft contained within this Petition for Exemption are multi

- rotor aircraft, t he Petitioner seeks exemption from 14 C.F.R 27 for the same reasons stated in the request for exemption from 14 C.F.R. 21(h).



### 14 C.F.R. 43.7 : Authorized Maintenance/Repair/Alteration PersonnelPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 26

Title 14, Part 43, Section 43.7 of the Code of Federal Regula tions regulates personnel authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration. Proposed conditions 13
and 14 are applicable to this particular regulation and the FAA has found in favor of previous Exemption #11208 pertaining to this rule. Furthermore, it is the opinion of the Petitioner that the stated rule would
create a burden as the Petitioner would have to find a regularly authorized conventional mechanic or otherwise licensed personnel to sign off on an unconventional flight craft’s maintenance. More clearly, it would be difficult to find a mechanic that specializes in Cessna Repair that is also an expert in s mall
radio

- controlled multi

- rotors.

Additionally, it is likely that the operator of the sUAS (the PIC) would be more knowledgeable on the interworking’s of their sUAS than a regular mechanic as they likely have past RC flying experience. Particularly, t he PICs working for the Petitioner will always have at least 25 hours of RC craft experience, in which time they will likely have to repair a prop for example. Due to the relative ease of replacing props on a multirotor (screw the broken one off and repla ce with a new one) it is not necessary for a certified or authorized individual to sign off on the repair. Instead, the repair can easily be done by authorized personnel working for the Petitioner so long as the conditions and procedures stated above,

are followed. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.7.



### 14 C.F.R. 43.11 : Dispositions of Records for Inspections

Title 14, Part 43, Section 43.11 of the Code of Federal Regulations pertains to the dis position of Records for Inspections. Proposed condition number 13 pertains to this particular regulation and the FAA has found in favor of previous Exemption #11208 which contained this rule. For the reasons stated in Condition 13 (“Proposed Conditions o f the Exemption”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.11.



### 14 C.F.R. 45.11 : Making of Products

Title 14, Part 45, Section 45.11 of the Code of Federal Regulations pertains to the manufacturing of
aircraft and ma jor aircraft components, including, but not limited, aircraft bodies, aircraft engines, and aircraft propellers. This particular rule requires various procedures for marking each component with fireproof markings and, in a manner acceptable to the Federal Aviation Administration, for purposes of
identification. Proposed Condition for Exemption #30 above, pertains to this particular regulation and the FAA has ruled on it in previous Exemption #11208. For the reasons stated in Condition #30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt
from 14 C.F.R. 45.11.



### 14 C.F.R. 45.23(b) : Display of Marks; GeneralPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 27

Title 14, Part 45, Section 45.23(b) of the Code of F ederal Regulations states that;

 “ When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.”

In a previous grant of exemption (Exemption #11062) it was determined by the FAA that the exemption of sUAS operators from this provision was warranted so long as the aircraft, “have identification (N

Number) markings in accordance with 14 C.F.R. 45 (c) if t he markings are as large as practicable.” As is stated in Proposed Condition #30 above, the Petitioner will mark their aircraft with markings as large as practicable and therefore should be exempt from 14 C.F.R. 45.23(b).



### 14 C.F.R. 45.27 : Marking of th e Aircraft

– Rotorcraft

According to Title 14, Part 45, Section 45.27, of the Code of Federal Regulations, the operator of a rotorcraft;

 Must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail, the marks require d by 14 C.F.R. 45.23.

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.27. More clearly, due to Condition #30 above, which states that the
Petitioner will mark the ir aircraft with markings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.27.



### 14 C.F.R. 45.29 : Size of Marks

According to Title 14, Part 45, Section 45.29, of the Code of Federal Regulations, the operator of a n aircraft;

 Must display on markings on the aircraft meeting the size requirements of this section  2

- 12 inches high depending on the aircraft type  Width 2/3s wide as the characters are high  1/6 th as thick as the characters are high  Not less than 1/4 th the character width  Uniform

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.29. More clearly, due to Condition #30 above, which states that the
Petitioner will mark t heir aircraft with markings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.29.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 28



### 14 C

. F

. R

. 61.3 : Requirement for Certificates, Ratings, and Authorizations

Title 14, Part 61, Section 61.3, of the Code of Federal Regulations pertains to the need for a Private Pilot’s license to operate an Unmanned Aerial Vehicle. The Petitioner seeks exemption from this rule to the extent that this rule requires a sUAS operator to hold a Private Pilot’s License. Clearly, the goal of this particular rule is to ensure the skill of any Pilot In Command matches the operating area in which they are flying. However, it is the Petitioner’s belief that the measure of a Private Pilot’s License and the training that went into it is not ne cessarily connected to that Pilot’s ability to operate a small unmanned aircraft at low altitudes. Particularly, the requirement of a Private License yields potential
PICs that have been trained in multi

- thousand pound, manned aircraft, flying at high alt itudes in comparison to 7.5 lbs. or less, battery

- powered craft, operated at 400 feet AGL or below. For this reason, it is the belief of the Petitioner that they be exempt from this rule as the requirement of a Private Pilot’s license is unnecessary. Fur thermore, it is sta ted as such on the FAA website. 7

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreatio nal or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

The authorization of Recreational and Sport Pilot Certificates as an alternative to a Private License points to a Private License as being a non

- requirement according to the FAA’s integration office. This further evidence shows that the Petitioner should be exempt from th e aforementioned regulation. Clearly, the Petitioner’s requirement of all PICs (Proposed Condition #4) to hold at least a Recreational or Sport Pilot’s Certificate yields an authorized level of training according to the FAA’s own website and in turn,
show s that such a requirement by the Petitioner offers an equivalent level of safety as is provided by existing rules.

Furthermore, Proposed Conditions #4, 6, 7, 8, and 9, among others, show the Petitioner’s commitment to safety and arguments for exemption f rom this rule.



### 14 C.F.R. 61.23(a) and (c) : Medical Certificates

– Requirements and Duration

According to Title 14, Part 61, Section 61.23 (a) & (c), of the Code of Federal Regulations, the operator of an aircraft is required to hold a Medical Certifica te in various Pilot In Command Situations. As is stated in Proposed Condition #4 above, the Pilot in Command will have at least a Sport’s Pilot’s License and at least a valid U.S. Driver’s license, which has been ruled by the FAA in previously granted exe mptions as a suitable alternative to a valid medical certificate for the authorized flights of unmanned systems. Furthermore, the FAA has posted on its website this new policy. 7 Due to Condition #4 above and thePETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 29

current F AA Policy displayed below, the Petitioner believes it should be granted exemption from 14 C.F.R. 61.23(a) and (c).

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptio ns by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilo t certificate.

 A third class medical certificate is no longer required. Now, a Section 333 operator only needs a valid driver’s license to satisfy the medical requirement. This change is consistent with the agency’s approach for sport pilot certificate h olders, who may fly light sport aircraft with a driver’s license and no FAA medical certificate. ”



### 14 CFR 61.101(e) (4) and (5) : Recreational Pilot Privileges and Limitations

In Title 14, Part 61, Section 61.101(e) (4) & (5), of the Code of Federal Regul ations, the FAA states that;

Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— for compensation or hire or in furtherance of a business.

As can be seen on the FAA’s website (https://www.faa.gov/news/updates/?newsId=82485);

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Pre viously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate.”

With the intention of Section 333 Exemptions being t he integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA do not adhere to 14 C.F.R. 61.101 (e) (4) and (5) and thus, it is the belief of the Petitioner that t hey should be exempt from 14 C.F.R. 61.101 (e) (4) and (5) because this Petition for Exemption is for the expressed purpose of conductin g commercial operations of sUAS in an effort to earn compensation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial sUAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate. Therefore, in all likelihood, many PICs employed by the Petitioner will have these specific Certificates and as such, will need to be able to fly for compensation.

Furthermore, as is stated on the FAA’s own website and as is highlighted below ;

“ The FAA a lso made two other changes to the Section 333 exemption process last week:PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 30

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at leas t a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

Therefore, it is highly likely that many potential PICs will have these Certificates as they are less costly and easier to obtain than a commercial Pilot’s License as an example. For these reasons, it is clear that the Petitioner should be granted an exemption from 14 C.F.R. 61.101 (e) (4) and (5).



### 14 CFR 61.113 (a) & (b) : Private Pilot Privileges and Limitation s

– Pilot In Command

Title 14, Part 61, Section 61.113 of the Code of Federal Regulations states that;

Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an air craft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an
aircraft.

Clearly this specific regulation conflicts with the Petitioner’s desire to provide commercial s UAS flights in the United States. Furthermore, some of the Petitioner’s PICs will have Private Pilot Licenses and as such they will be operating an aircraft (the sUAS) for compensation or hire under the proposed Petition for Exemption.

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA, including a private pilot’s license

, do not adhere to 14 C.F.R. 61 .113 and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.113 because this Petition for Exemption is for the expressed purpose of conducting commercial operations of s UAS in an effort to earn compensation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial s UAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Re creational or Sport Pilot Certificate (but who may also hold a Private License). In addition, the FAA has granted over 800 Section 333 Exemptions to businesses and individuals looking to provide commercial/compensation

- based sUAS flights.

Furthermore, l ooking at 61.113 (b), which states; A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

 The flight is only incidental to that business or employment; and  The aircraft doe s not carry passengers or property for compensation or hire.

The Petitioner seeks exemption from these rules as it is the Petitioner ’ s goal to fly s UAS missions for compensation or hire. Additionally, the specific provision pertaining to not flying aircr aft that carry property for compensation or hire is something the Petitioner would like to be exempt from as well

.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 31

Various forms of property may be carried on a s UAS, including; Camera Systems, Digital Imagery,
Sensors , and the like.

For all these reaso ns , the Petition er seeks exemption from 14 C.F.R. 61.113 (a) and (b).



### 14 C

. F

. R . 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

In Title 14, Part 61, Section 61.315(a), of the Code of Federal Regulations, the FAA states that;

If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section. Paragraph (c) reads the following;

You may not act as pilot in command of a light

- sport aircraft:

(1) That is carryin g a passenger or property for compensation or hire.

(2) For compensation or hire.

(3) In furtherance of a business.

(4) While carrying more than one passenger.

(5) At night.

(6) In Class A airspace.

(7) In Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower unless you have met the requirements specified in §61.325.

(8) Outside the United States, unless you have prior authorization from the country in whic h you seek to operate. Your sport pilot certificate carries the limit “Holder does not meet ICAO requirements.”

(9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft salesperson.

(10) In a passenger

- carrying airlift sponso red by a charitable organization.

(11) At an altitude of more than 10,000 feet MSL or 2,000 feet AGL, whichever is higher.

(12) When the flight or surface visibility is less than 3 statute miles.

(13) Without visual reference to the surface.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 32

(14) If the ai rcraft:

(i) Has a VH greater than 87 knots CAS, unless you have met the requirements of §61.327(b).

(ii) Has a VH less than or equal to 87 knots CAS, unless you have met the requirements of §61.327(a) or have logged flight time as pilot in command of an ai rplane with a VH less than or equal to 87 knots CAS before April 2, 2010.

(15) Contrary to any operating limitation placed on the airworthiness certificate of the aircraft being flown.

(16) Contrary to any limit on your pilot certificate or airman medical certificate, or any other limit or endorsement from an authorized instructor.

(17) Contrary to any restriction or limitation on your U.S. driver's license or any restriction or limitation imposed by judicial or administrative order when using your driver's license to satisfy a requirement of this part.

(18) While towing any object.

(19) As a pilot flight crewmember on any aircraft for which more than one pilot is required by the type certificate of the aircraft or the regulations under which the flight is c onducted.

The Petitioner requests exemption from numerous provisions contained in 14 C.F.R. 61.315 (a)(c). Particularly, the Petitioner requests exemption from the following subparts of 14 C.F.R. 61.315 (c); 1, 2, 3, 9, and 18. Furthermore, the Petition er believes that the remaining subparts (4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19) will be adhered to via proposed conditions conta ined in “ Proposed Conditions of the Exemption ” above. Specifically, subparts 4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19 are covered by Proposed Conditions 1, 6 & 24, 6, 6, 1, 1, 3, 6 & 28, 6 & 28, 5, 25, 25, and 4 respectively.

Additionally, pertaining to subparts 1, 2, 3, 9, 18, and 19, the Petitioner seeks ex emption due to both unnecessary burdens on the Petitioner as well as an equivalent level of safety as is provided by these existing subparts of 14 C.F.R. 61.315 (a)(c). Arguments for each subpart are contained below.

Subpart (1) of 14 C.F.R. 61.315 (c) st ates that a Sport

- Certified Pilot may not operate an aircraft if that aircraft is carrying passengers or property for hire/compensation. This is an unnecessary burden on the Petitioner as;

1. They will not be carrying any pass e ngers as they are flying Unmann ed Systems, and;
2. There will be situations in which the Petitioner carries property for compensation.

The most likely of these situations will happen when a Petitioner is carrying a device or measurement tool owned by another person for compensation. This may includ e an imaging sensor owned by a third party for example. If a third party company owns the actual sensor but wants the Petitioner to utilize the tool on the Petitioner’s aircraft, the Petitioner will be flying with property for compensation. Thi s compensation is related to the risk of loss while the camera is operating on the Unmanned System as well as the aerial perspecti ve achieved by the sensor on a s UAS that would otherwise be impossible toPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 33

obtain if th e partner company only had the sensor. This example is common in many industries in which ground tools (such as cameras) are utilized on unmanned systems. Without exemption from this rule the Petitioner would have to either purchase the 3rd par ty sensor for use on their own s UAS or forego the compensation opportunity because they cannot carry the client’s tool and thus, not get the information the client desires. For this reason, it would be a significant burden to utilize a s UAS commercially without the ability to carry multiple sensors that may not be personally owned by the
Petitioner.

Furthermore, it is the belief of the Petitioner that an equivalent level of safety would be provided if exempt from this rule because of the extensive trai ning the PIC would have on the s UAS prior to flying

co mmercially. This training will be in excess of the existing requirement to have at least a Sport Pilot’s or Recreational Certificate . Thus, the PIC will have sufficient manned aircraft and unmanned aircraft
traini ng to successfully operate the s UAS witho ut endangering the public. The training procedures and training materials for the PIC can b e found in Exhibits 1 and 4 below.

In addition to subpart (1) of 14 C.F.R. 61.315 (a)(c), the Petitioner also requests exemption from subpart (2) which states tha t an operator with a Sport Pilot’s License may not operate an aircraft for compensation. As has been highlighted previously, the directive from Congress passed to the FAA via the FAA Modernization and Reform Act of 2012 was to integrate commercial UAV ope rations into the National Airspace System. Furthermore, in numerous previously filed and granted Petitions for Exemption under Section 333, it has been stated by the FAA that;

 The agency now allows operations under these exemptions by people who hold a

re creational or sport pilot certificate.

This statement, combined with the initiative behind Section 333 exemptions (the commercial integration of UAV operations in the National Airspace System) shows that the FAA has found in favor of the idea that commerc ial UAV operations can be conducted by people who hold a recreational or sport pilot certificate. Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R. 61.315 (a)(c), which states that a Sport

- Certified Pilot may not operate a n aircraft in furtherance of a business. The FAA defines “Furtherance of a Business” as;

 A flight, even if incidental to your employment or the business you intend to conduct, and not required by your business or employment, would be considered “in furthe rance of a business.” 10

Clearly, based on this description, an aerial operation that is “in furtherance of a business” would be considered a lesser form of commercialization than flights for hire or compensation as these ty pes of flights are incidental to a business as opposed to directly related to the business, which is what a flight for compensation would likely be. Therefore, it is the belief of the Petitioner that they be exempt from this rule for the same justificatio n as is proposed regarding 14 C.F.R. 61.315 (a)(c) (1) and (2).

On top of subparts (1), (2), & (3) of 14 C.F.R. 61.315 (a)(c), the Petitioner also seeks relief from subpart (9) which states that a Sport

- Certified Pilot may not operate an aircraft to demo nstrate that aircraft for sale. The Petitioner seeks exemption from this rule as they will be carrying an inventory/stock/fleet of UAV aircraft in an effort to operate a commercial service business. Furthermore, this inventory/stock/fleet will turnover fr om time to time as new aircraft are added and old aircraft arePETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 34

released by the company. In this event it will be important for the Petitioner to have the capability of showing off the aircraft to prospective buyers so that they can get the best price for their used systems. Plus, with PICs already being heavily trained and experienced with commercial flights, there is no added risk to allowing a qualified PIC to demonstrate the aircraft for sale to prospective buyers. The demonstration after all would be equivalent or less dangerous than a commercial flight that the PIC already performs on a frequent basis as part of their job as a commercial s UAS Pilot.

The Petitioner also seeks exemption from 14 C.F.R. 61.315 (c) (18) which states that a Sport

- Certifi ed Pilot may not operate an aircraft while towing an object. It is the belief of the Petitioner that they be exempt from this rule as the maximum takeoff weight of their aircraft will never exceed the max takeoff weight specifications highlighted by the m anufacturer. These max takeoff weights are the maximum weight these aircraft can carry (including themselves) and still fly effectively. Thus, any object being towed by the aircraft will have to weigh equal to or less than the maximum allowable weight in order to maintain or come under the max takeoff weight specifications highlighted by the manufacturer. Additionally, Proposed Condition 36 f rom the “ Proposed Conditions of the Exemption ” above, highlights

reason ing as to why the Petiti oner believes their commercial s UAS flights in which objects are towed, would provide an equivalent level of safety as is provided by the existing rule. Particularly, the required and additional training necessary for a PIC to beco me an Object Towing PIC shows the skills that would be required to tow objects.

Furthermore, with the continued innovation in the world of sensors, it will be necessary for the Petitioner to be able to tow objects, such as tow

- behind sensors, in order to remain competitive with their competition. Tow

- behind sensors might measure air quality , capture imagery, or perform various other data collection methods. Competing vehicles for these tow

- behind sensors would include ATVs, Motorcycles, Manned Aircraft, and the like. All of these potential alternatives are more expensive to operate, more dangerous to operate, and dirtier to operate. Each alternative would cost multiple thousands of dollars to purchase, are larger, powered by combustion engines, and carr y flammable fuel. Additionally, they produce negative effects on the environment. For the reasons stated above, the Petitioner believe s they should be exempt from 14 C.F.R. 61.315 (c) (18).



### 14 C.F.R. 91.7(a) : Civil Aircraft Airworthiness

Title 14, Part 91, Section 91.7 (a) of the Code of Federal Regulations states; no person may operate a civil aircraft unless it is in an airworthy condition. Proposed Condition #13 pertains to this particular regulation and the FAA has found in favor of previous Exempt ion #11062, 11063, and 11064, which contained this rule. For the reasons stated in Condition 13 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R . 91.7 (a) and the proposed condition offers an equivalent level of safety as is currently provided by the existing rule.



### 14 C.F.R. 91.9(b)(2) : Civil Aircraft Flight Manual

Title 14, Part 91, Section 91.9 (b) (2) of the Code of Federal Regulations states ;PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 35

No person may operate a U.S.

- registered civil aircraft for which an Airplane or Rotorcraft Flight Manual is not required by Part 21.5 of this chapter, unless there is available, in the aircraft, a current approved Airplane or Rotorcraft Flight Manual, a pproved manual material, markings, and placards, or any
combination thereof

. Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemption s #11062, 11063, and 11064, which contained a request for exemp tion from this rule. For the reasons stated in Condition 20 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (b) (2). Furthermore, the pr oposed condition offers an equivalent level of safety as is currently provided by the existing rule as the Operating manuals about which this rule pertains are available to the operator at all times on the ground, just as they would be if
the aircraft was carrying the operator. Thus, any information the operator desires about the aircraft or its operating guidelines, can be found within documents within arm’s reach of the operator or on a digital device, such as a Smart Phone or tablet , easily accessible t o the operator.



### 14 C.F.R. 91.9(c) : Civil Aircraft Marking, Placards

Title 14, Part 91, Section 91.9 (c) of the Code of Federal Regulations states; No person may operate a
U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

. Proposed Condition #30 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Condition 30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (c). Furthermore, t he proposed condition offers an equivalent level of safety as is currently provided by the existing rule as the FAA has previously determined that exemption from these requirements is warranted provided that the aircraft “have identification (N

- Number) mar kings in accordance with 14 C.F.R. Part 45, Subpart c, if the markings are as large as practicable.” 11



### 14 C.F.R. 91.103 : Preflight Action

Title 14, Part 91, Section 91.103 of the Code of Federal Regulations states;

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecas ts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 36 (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civi l aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Proposed Conditions # 3, 6, 12, 1 6, 17, 20, 22, 23, 24, and 28 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemptions #110 62, 11063, and 11064. For the reasons stated in Conditions 3, 6, 12, 16, 17, 20, 22, 23, 24, and 28 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C .F.R. 91.103. Furthermore, the proposed conditions offer an equivalent level of safety as is currently provided by the existing rule as Preflight Planning is integral to the Petitioner’s sUAS flights and each mission will be carefully planned, taking into consideration weather, power requirements, aircraft operating guidelines, and more, as seen in the proposed conditions above.



### 14 C.F.R. 91.105 : Flight Crewmembers at Stations

Title 14, Part 91, Section 91.105 of the Code of Federal Regulations state s;
(a) During ta keoff and landing, and while en route, each required flight crewmember shall

—
(1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircraft or in connection with physio logical needs; and

(2) Keep the safety belt fastened while at the crewmember station.

(b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or h er assigned duty station. This paragraph does not apply if

—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

(2) The crewmember would be unable to perform required duties with the shoulder harness fastened.

Propose d Condition #4 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption #11185. For the reason stated in Condition #4 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.105. Furthermore, 14 C.F.R. 91.105 doesn’t really apply to the Petitioner ’s aircraft as all the aircraft requested b y the Petitioner weigh below 10 lbs. and do not carry a physical crew. As such, there is no cockpit or other operating area within the vehiclePETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 37

where a prospective crewmember would harness themselves in. Instead, all operations of the sUAS are
executed fr om the ground from a designated operating area, in which, each crewmember has an assigned position at which they will stand during the operation. Generally, this standing area would be near the ground station for the PIC and in a pre

- designated area (whic h is determined by the PIC) for the VO. Utilizing pre

- determined standing areas for both the PIC and VO will ensure safe operating procedures of the Unmanned Vehicle.



### 14 C.F.R. 91.109 : Flight Instruction

Title 14, Part 91, Section 91.109 of the Code of Federal Regulations states;

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be give n in an airplane that is equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

—
(1) The instructor has determined that the flight can be conducted safely; and

(2) The p erson manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, d ual controls may be used for flight instruction to conduct a flight review required by§ 61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency
check required by § 61.57 when

—
(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight;

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of§ 61.195(b ) , and has logged at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be conducted safely.

(c) No person may operate a civil aircraft in simu lated instrument flight unless

—
(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning
dual control s. However, simulated instrument flight may be conducted in a single

- enginePETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 38

airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when

—
(i) The safety pilot has determined th at the flight can be conducted safely; and

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for apart 121 proficiency flight test, unless the pilot seated at the controls, other than the pi lot being checked, is fully qualified to act as pilot in
command of the aircraft.

Proposed Conditions #4, 7, 8, and 9 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from t his rule, including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions #4, 7, 8, and 9 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.109.



### 14 C.F.R. 91.113(b) : Right

- of

- Way Rules

Title 14, Part 91, Section 91.113(b) of the Code of Federal Regulations states;

(b) General. When weather conditions permit, regardless of whether an operation is conducted under
instrum ent flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

of

- way, the pilot shall give way to that aircraf t and may not pass over, under, or ahead of it unless well
clear.

Proposed Conditions #6 and 32 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Ex emption #11238. For the reasons stated in Conditions #6 and 32 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.113(b). Due to the fact
tha t all the Petitioner’s sUAS operations will take place under the guidance of a PIC and VO within Line of Sight of the aircraft, it is the belief of the Petitioner that their proposed operations offer an equivalent level of safety as is provided by the exis ting rule.



### 14 C.F.R. 91.119 : Minimum Safe Altitudes

Title 14, Part 91, Section 91.119 of the Code of Federal Regulations states;

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 39

(a) Any where. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of person s, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FA A; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Proposed Conditions #3, 6, 25, 26, 28, 29, and 34 pertain to this particular regulation and the FAA h as found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Conditions #3, 6, 25, 26, 28, 29, and 34 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.119.

Each of the Proposed Conditions above create sUAS operations with equivalent safety to what the typical manned mission under 14 C.F.R. 91.119 would provide. Remember, when co mparing to manned operations with manned flight craft, a sUAS is much smaller and light

- weight. Consider the fact that a manned aircraft weighs thousands of pounds, carries flammable fuel, and is powered by a combustion engine. Clearly, carrying out a mi ssion utilizing a sUAS would provide for a safer operation than would a
conventional aircraft under 14 C.F.R. 91.119.



### 14 C.F.R. 91.121 : Altimeter Settings

Title 14, Part 91, Section 91.121 of the Code of Federal Regulations states;

(a) Each person opera ting an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—
(1) Below 18,000 feet MSL, to

—
(i) The current reported altimeter setting of a station a long the route and within 100 nautical miles of the aircraft;PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 40 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atm ospheric pressure in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27 .91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under§§ 91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

Proposed Condition #3 pertains to this particular re gulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on the idea that an equivalent level of safety could be provided so long as the Unmanned Aircraft wasPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 41

operated below 400 feet AGL, within Visual Line of Sight, and operated with a live, GPS

- based, Altitude
read

- out. For the reasons stated in Condition #3 (“ Proposed Conditions of the Exemption ”) above, it is
the belief of the Petitioner that they be exempt from 14 C.F.R. 91.121 because they are receiving a live,
GPS

- Altitude, read

- out on each flight, they are operating below 400 feet AGL, and they are operating within Visual Line of Sight. Furthermore, as can be seen in Proposed Condition #3, each flight conducted by the Petitioner will begin with a zero

- altitude start point.



### 14 C.F.R. 91.151(a) : Fuel Requirements for VFR Flight Conditions

Title 14, Part 91, Section 91.151(a) of the Code of Federal Regulations states;

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

—

(1) During th e day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Proposed Condition #17 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aer ial, which contained a request for exemption from this rule based on an equivalent level of safety being provided by a sUAS when ending a flight with at least 25% battery life remaining. Clearly, a percent battery life remaining is a better measure for sa fety when using a sUAS because the current battery capacities achieved by these types of v ehicles (including all the sUAS proposed in this Petition for Exemption) often do not allow for flight times of over 25 minutes, which is
far less than even the reser ve time limits mandated by 14 C.F.R. 91.151(a). For the reasons stated in Condition #17 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.151 (a) because they can achieve an equivalent level of safety by terminating their flights with 25% battery life remaining.



### 14 C.F.R. 91.203(a) and (b) : Civil Aircraft

– Certifications Required

Title 14, Part 91, Section 91.203(a) and (b) of the Code of Federal Regulations states;

(a) Except as provided in§ 91.715 , no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under§ 21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that por tion of thePETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 42

operations specifications issued under § 21.197(c) , or an authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapter

. However, the airworthiness certificate need not have on it a n assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft may only be obtained upon application to an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft Registration Application as provided for in§
47.31 (c) , or a registration certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under§ 91.7 15 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Exemptions #11062, 11063, and 1 1064, which contained a request for exemption from this rule. Additionally, all required paperwork will be available to the PIC and VO on the ground as these are Unmanned Systems as opposed to manned aircraft. This paperwork may be in
hard

- copy form or a vailable through a link on the internet, such as a Google Drive account for example.



### 14 C.F.R. 215 : ATC Transponder and Altitude Reporting Equipment and Use

Title 14, Part 91, Section 91.215 of the Code of Federal Regulations states;

(a) All airspace: U.S.

- registered civil aircraft. For operations not conducted under part 121 or 135 of this chapter , A TC transponder equipment installed must meet the performance and environmental requirements of any class of TSO

- C74b (Mode A) or any class of TSO

- C74c (Mode A with altitude reporting capability) as appropriate, or the appropriate class of TSO

- C112 (Mode S)

. (b) All airspace. Unless otherwise authorized or directed by ATC, no person may operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless that aircraft is equipped with an operable coded radar beacon trans ponder having either Mode 3/A 4096 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC and intermode and Mode S interrogations in

ac cordance with the applicable provisions specified in TSO C

- 112, and that aircraft is equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure altit ude information in 100

- foot increments. This requirement applies

—
(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part fro m the surface upward to 10,000 feet MSL;PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 43

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system insta lled, balloon or glider may conduct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are conducted

—
(i) Outside any Class A, Class B, or Class C airspace area; and

(ii ) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B or
Class C ai rspace area designated for an airport upward to 10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system install ed, balloon, or glider

—
(i) In all airspace of the 48 contiguous states and the District of Columbia at and above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the surface; and

(ii) In the airspace from the surface to 10,000 feet MSL within a 10

- nautical

- mile radius of any airport listed in appendix D, section 2 of this part, excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designated for that airport.

(c) Transponder

- on operation. While in the airspace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equipped with an operable ATC transponder maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.

(d) ATC authorized deviations. Requests for ATC authorized dev iations must be made to the ATC facility having jurisdiction over the concerned airspace within the time periods specified as follows:

(1) For operation of an aircraft with an operating transponder but without operating automatic pressure altitude repo rti ng equipment having a Mode C apability, the request may be made at any time.

(2) For operation of an aircraft with an inoperative transponder to the airport of ultimate destination, including any intermediate stops, or to proceed to a place where suitable repairs can be made or both, the request may be made at any time.

(3) For operation of an aircraft that is not equipped with a transponder, the request must be made at least one hour before the proposed operation.

Proposed Conditions #3, 25, 26, and 27 p ertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions, and particularly all the reporting requirements contained in an
ATO

- Issued COA, the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with reporting standards as set forth in the rule.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 44



### 14 C.F.R. 91.403 : General

Title 14, Part 91, Section 91.403 of the Code of Federal Regulations states;

(a) The owner or operator of an aircraft is pr imarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter

. (b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this s ubpart and other applicable regulations, including part 43 of this chapter

. (c) No person may operate an aircraft for which a manufacturer's maintenance manual or instructions
for continued airworthiness has been issued that contains an airworthiness limi tations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set forth in an operations specification approved by the Administrator underpart 121 or 135 of this chapter or in accordance with an inspection program approved under § 91.409(e) have been complied with.

(d) A person must not alter an aircraft based on a supplemental type certificate unless the owner or operator of the airc raft is the holder of the supplemental type certificate, or has written permission
from the holder.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.405(a) : Maintenance Required

Title 14, Part 91, Section 91.405(a) of the Code of Federal Regulations states;

Each owner or operator of an aircraft

—
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepa ncies repaired as prescribed in part 43 of this chapter ;

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as i s provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 45



### 14 C.F.R. 91.407(a)(1) : Operation after Maintenance or Alteration

Title 14, Part 91, Section 91.407(a)(1) of the Code of Federal Regul ations states;

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—
(1) It has been approved for return to service by a person authorized under§ 43.7 of this chapter.

Proposed C onditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 409(a)(1) and (2) : Inspections

Title 14, Part 91, Section 91.409(a)(1) and (2) of the Code of Federal Regulations states;

(a) Except as provided in paragraph (c) of this section, no person ma y operate an aircraft unless, within the preceding 12 calendar months, it has had

—
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed C onditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.417(a) and (b) : Maintenance Records

Title 14, Par t 91, Section 91.417(a) and (b) of the Code of Federal Regulations states;

(a) Except for work performed in accordance with§§ 91.411 and 91.413 , each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 46

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engin e, propeller, rotor, and appliance of an aircraft.
The records must include

—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return
to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of l ife

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of th e aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by§ 43.9(d) of this chap ter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of t his section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred
with the aircraft at the time t he aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

Proposed Conditions #13, 14, and 15 p ertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as se t forth
in the rule.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 47



## Privacy

When discussing the use of Small Unmanned Aerial Vehicles, the question of privacy frequently comes up. The reason for this is clear as small unmanned aircraft, despite their incredible uses as a tool, also have the poten tial to be used for nefarious activities, such as spying for example. This presents a risk to the personal privacy of individuals. Furthermore, in less extreme cases of invasion of privacy, a small unmanned craft might accidently capture imagery that wou ld comprise someone’s privacy. Due to these potential privacy risks it is imperative for operators of small unmanned craft to use their aircraft responsibly and focus on mitigating any of the potential privacy risks their aircraft creates. The
Petitioner is particularly aware of the privacy concerns of individuals and due to this is extremely focused on providing privacy not only for individuals, but also for customers.


## Public Interest and Safety

According to the Federal Aviation Administration Guideli nes for Section 333 Exemptions there are three main criteria a successful Petition for Exemption under Section 333 should have;

1. The Petitioner must submit a request for exemption from a rule or set of rules contained in 14

C

. F

. R

. that the Petitioner believ e s will be a burden for their operations.

2. The Petitioner must provide a level of safety at least equal to that provided by the rule from which the Petitioner is seeking a n exemption, and;

3. The Petitioner’s request must be in the Public Interest.

To satisf y these main guidelines, the following information will cover the justification of the proposed commercial operations under Section 333 requested by this Petition. More clearly, the following arguments will show how each of the proposed applications/use

- c ases are in the public interest and promote safety.

Specifically, the sUAS flights proposed in this petition will increase safety for the following applications; Agriculture, Cinematography, Environmental Protection, F ire, Insurance, Land Inspection, Real Estate,
and Search and Rescue. Furthermore, it wi ll be seen that the use of sUAS by the Petitioner will also promote safety and reduce negative environmental impacts. This will be achieved because of the lower
risk s associated with a small, plastic, battery

- powered sUAS, as compared to a manned, multi

- thousand

pound, combustion

- engine

- powered, flammable

- fuel

- carrying aircraft. Plus, with most sUAS data capture happening at low altitudes, because of the enhanced da t a resolution possible at low altitudes, customers of sUAS services are getting better, more accurate data, while at the same time the public is avoiding the potentially hazardous practice of ultra

- low

- flying manned aircraft. Clearly, the combination
of be tter, more accurate data, coupled with the enhanced safety of a sUAS over manned aircraft, produces a viable commercial operation that promotes the public interest. Evidence of this can be found in the industry

- specific examples below.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 48

In addition to th e aforementioned safety benefits and promotion of public interest s, it should also be
noted that all sUAS utilized by the Petitioner satisfy the directives passed to the Federal Aviation Administration by Congress in t he Reform Act of 2012 . Specifically, all of the Petitioner’s aircraft satisfy the size, weight, speed, operating capabilities, proximity to airports, proximity to populated areas, and visual line of sight rules and requirements laid out by Congress. Furthermore, due to the FAA precedent
of r equiring, at minimum, a Sport Pilot’s Certificate, the FAA can be assured that all commercial flights proposed in this Petition do not pose a threat to National Security as all PIC’s will have already been vetted by the Department of Homeland Security. Fo r these reasons and for the numerous arguments contained herein, this Petition for Exemption provides strong justification for approval of commercial operations for the above

- stated sUAS in the above

- stated applications and use

- cases under Section 333,

pur suant to the operating procedures and requirements described herein.

Furthermore, contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate commercial sUAS flights into the National Airspace System. With this initiative it is definitive that Congress believ es that the integration of commercial sUAS into the National Airspace System is within the Public Interest as they are, obviously, elected representatives of the public assigned with the duty of driving polic y that promotes the Public Interest. Thus, in addition to the industry

specific examples below, it should also be considered t hat the integration of all sUAS , pursuant to their safe integration to the NAS and providing of at least an equivalent level of s afety as is provided by the current FAA rules, is inherently within the public interest.

Please look below to find more detailed descriptions as to why each of the applications highlighted above can provide a benefit to the public as a whole and r easons why the exemption would not adversely affect safe ty

.



### Agriculture Precision Agriculture is an industry that has seen a significant influx of sUAS u se over the past few years. With this influx of Unmanned Aerial Vehicle Technologies, farmers and their Ag partners have become more efficient and effective in making various Ag

- related management decisions.

There is an adage that points to the importan ce of agriculture to the public that reads, “...once in your life you need a doctor, a lawyer, a policeman, and a preacher, but every day, three ti mes a day, you
need a farmer.” 13 This adage really highlights the importance of agriculture to the public as a whole, as the Ag industry, and particularly farmers, are the people who provide the general public with one of their three essential needs, food.

What sUAS provide to the Ag Industry are a method by which to collect information and make management decisio ns that are more data

- driven and thus, more effective. Consider the use of sUAS to provide targeted scouting and aerial imaging/mapping to farmers and their Ag partners (Agronomists, Crop Consultants, Seed Dealers, etc.).

Every year millions of acres of farmland are scouted by a variety of people, whether it is the farmers themselves, or an Ag partner of theirs, such as a Cooperative Agronomist, Crop Consultant, Field Intern, or other third party Ag partner. The idea behind scouting is to collect in

- sea son information about the crops and fields in question. As an example, a typical crop scouting intern will get a set of field maps from their boss at the Coop every morning. These field maps will be for a variety of fields and crop typesPETITIONER

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around the area and owned by a variety of farmers. The task of these interns is to go out in those fields and collect information relating to; Nutrient Deficiencies, Insect Pressure, Plant Diseases, Compaction, Plant Populations, and the like. They then take this inform ation and report back to their agronomist or directly to the farmer. The farmer then takes this information and makes management decisions based
on it.

As an example, the scout might take a tissue sample while in the field, send it to the lab, and recei ve the results. The results of the field in question may be low on a variety of nutrients (ex. Macro Nutrients

– Nitrogen, Phosphorous, Potassium; Micro Nutrients

– Boron, Sulfur, Manganese, Zinc, etc.). The farm
will then take this information and reali ze that they are low on Nitrogen and Boron and that they should make a fertilizer application of these two nutrients to improve their crop.

The example above really highlights how a Precision

- focused farmer utilizes information to make a management decis ion and thus, increase yields and grow more food. This is obviously in the public interest as it is estimated by the UN’s Food and Agricultural Organization (“FAO”) that by the year 2050 Global Food Production will have to increase by 70% of where it is t oday in order to feed a population
that is estima ted to grow to over 9 billion. 14

Where sUAS come into play is that they provide even more efficiency and data

- driven decision

- making than we even use today. Why is this? It is because a sUAS can provide a new perspective to look at agricultural crops and in turn provide a new data

- set from which information can be derived and decisions can be made. Consider the same example as we highlighted above, with the crop scout walking a set of fields, taking a tiss ue sample, and returning the lab data to the farmer so that the
farmer can make an In

- Season management decision. Now consider this example if that crop scout were equipped with the same types of sUAS utilized by the Petitioner.

First of all, the scout wo uld be much more efficient. A recent study at the University of Wisconsin

Whitewater showed that scouting with a sUAS was up to 80% more efficient than walking an entire
field. 15 Considering this efficiency fact alone, a scout is going to be much more ef ficient each day, which allows him/her to scout more acres and thus provide more information to more farmers to make data

driven decisions and produce more food as a whole. However, efficiency is not the only benefit.

In addition to efficiency, a scout can also be more targeted, meaning they can pinpoint areas of the field most in need of a thorough walk

- through and go straight to those spots as opposed to walking randomly through the field (which is the standard practice for many scouts). By gaining an aerial perspective with a sUAS, scouts can view the entire field or orchard in a video or picture quickly and in turn, see blotches of discoloration or diseased crop instantly. Using the internal GPS Guidance System onboard the aircraft, this scout can a lso georeference their imagery, meaning each picture they take can be tagged
with a Geo

- coordinate (Latitude and Longitude). This allows them to pinpoint an area of distress in the field, get the geo

- tag, input it into their Smart Phone or Tablet, and wal k straight to that area of distress. This is both efficient and vital to the farmer and his crop. While a typical crop scout might completely miss a distressed area of a field (due to the lack of an aerial perspective), a targeted scout with a sUAS is

go ing to have the opportunity to point out all the issues in the field and in turn manage those areas to minimize the damage (yield loss).

In addition to the basic benefits provided by a sUAS in terms of efficiency and targeted scouting of problem areas, t here is also the benefit of using more advanced payloads to pull even more informationPETITIONER

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from an aerial assessment utilizing a sUAS. Consider the increasing popularity of Near

- Infrared and Thermal Infrared Imaging payloads. Both these payload types provide information to the farmer that can help in management decisions and management practices.

A Near Infrared Imaging Payload, like the Tetracam ADC Snap or Micasense RedEdge for example, can provide information relating to the Near Infrared light reflectan ce bouncing off an Agricultural crop. This data is not viewable to the naked eye and is not “capturable” by a standard visible

- light spectrum digital camera. However, this data can be extremely important and suggest crop stress within a field. By utiliz ing a sUAS, an operator like the Petitioner could provide a new data layer for his farm that could help hi m det ermine plant stress within his fields and map it according to the georeferenced, stitched imagery. Additionally, this type of imagery could also assist in management practices. With a stitched orthomosaic, like the ones created using NIR & georeferenced Imagery, farmers can create management zones in their fields using Ag software and even create georeferenced prescription maps, which are
utilize d to variable

- rate fertilizers and chemicals onto fields.

Using this type of data and software minimizes over and under application of chemicals and fertilizers and ensures the right amount of product is applied to each acre of the field. This will serv e the public interest by creating a healthier environment with less runoff and water contamination as well as provide for more sustainable farming practices. Plus, all of this is done by making data

- driven chemical and fertilizer applications derived from sUAS Imagery, which in turn saves the farmer money by using the correct amount of product and ensures maximum yields by optimizing the application so that each acre of farmland receives exactly the amount of product it needs based on plant stress.

The abo ve example mostly pertains to Precision Agriculture, however it should be noted that there are a variety of applications in agriculture outside Precision Agriculture that can also be positively impacted by sUAS use. Cattle operations as an example can mon itor the health of their cattle by flying over their herds with thermal cameras. Plant operators can monitor the temperature of their grain piles by utilizing these same thermal cameras in much the same way. So clearly, there are many applications in
the Ag Space that could utilize sUAS.

Furthermore, it should also be considered that these steps forward in efficiency and management practices are done while utilizing a safe and effective sUAS Tool that is not only maintaining the safety of
the National Airspace but also taking into consideration customer and public privacy as well as eliminating the risks associated with the alternative form of imagery capture using a manned aircraft.

Referring back to the 4

- D analysis of UAV use, it is clear that the agricultural applications of data capture point to the use of UAV systems over manned aircraft because;

 Dull

– Ag flights require repetition as crop stress and/or animal health needs to be checked frequently. In some applications, daily or even hourly fl ights may be necessary. Due to this requirement of high repetition, a sUAS is well suited for the job over a manned aircraft, which would basically require a full time pilot on

- call 24 hours a day.

 Dangerous

– Ag flights have the potential to carry a hi gh degree of risk, especially when flying low over crops or cattle. Really, any low altitude flight in a manned aircraft is more dangerous than a high altitude flight because of the increase in obstacles and less margin forPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 51 error. It is for this reason t hat Crop Dusting is a dangerous industry as pilots are operating
manned aircraft at altitudes much lower than their Private and Commercial Pilot counterparts. Furthermore, utilizing a sUAS fly

- over in agriculture can produce safer operations when compared to the alternative.

 Dirty

– Ag flights have the potential to be carried out in hazardous environments. As stated above, operating at low altitudes is a hazardous environment and an environment which is better navigated by a non

- human, such as a sUAS

. This is particularly the case if a chemical application has recently been applied to the crop. It would be much better to send a UAV around the field to capture high resolution pictures of the crop canopy than to have a human walk through it and expose themselves to potentially hazardous chemicals.

 Deep

– Ag flights can sometimes be beyond the range of manned platforms. First, sUAS have the ability to fly at lower altitudes and thus capture higher resolution data than what a
manned aircraft could do. Additionally, flights around structures on a farm or near a farm (such as silos, barns, radio towers, etc.) could potentially be hazardous for a manned aircraft
while a micro

- drone has a lot more maneuverability in tight spaces.

Therefore, the promo tion of the public interest described above coupled with the enhanced safety provided by sUAS flights in Agriculture, strongly supports the granting of this petition.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Agriculture Industry as being within the public interest.

 Exemption Numbers:

o 11110

o 11136

o 11167

o 11192

o 11222



### Cinematography

The Aerial Cinematography Industry is an industry that has been operating for many years to capture
cinema

- quality footage from low altitudes. Initially this type of cinematography was captured using fixed wings and helicopters, but in more recent years , the business has started to util ize UAVs. The reason the industry has transitioned to these small aircraft is because newer UAV systems have been able to capture the quality video the industry is looking for but at a much lower cost and with significant ly lower risks.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 52

One of the reasons manned aircraft cinematography is so expensive is because of the dangers associated with flying a 6,000 pound aircraft, filled with flammable fuel, powered by a combustion engine, at low altitudes and over people. The insurance costs alone for these types of activities are high and accidents have happened in the industry. Some of these accidents have even lead to casualties. Earlier this year 10 people died when two helicopters crashed while filming the French Realty Show, “Dropped.” 16 Whenever you have manned aircraft operating at low altitudes there are added risks. These risks include ground structures, confined spaces, and more. Additionally, when you have manned aircraft, any accidents are much more catastrophi c than if you had the same situation with unmanned aircraft. Once again, this is because of the size and flammable fuel carried on

- board manned aircraft. A small Unmanned Aircraft does not have these attributes, plus, because there are no people on board

, the chances of causalities is lower because there is no pilot.

It is important to remember that the weight of the UAVs utilized by the Petiti oner will weigh no more
than 10 pounds and contain no crew, flammable fuel, or combustion engine. This limited weight and size will significantly reduce the potential for casualties or mass property damage in the case of a crash. Furthermore, the use of electric power by the Petitioner’s UAVs is much more environmentally

- friendly than that of a manned aircraft, w hich is carrying a significant amount of unnecessary weight using
carbon

- based fuel sources. Therefore, in addition to the increased safety obtained by a UAV performing aerial cinematography, there is also the added public benefit of a healthier environme nt.

Furthermore, while traditional aerial cinematography utilizing conventional aircraft can perform in close proximity to people and property, it should be pointed out that a UAV is even safer than the traditional methods because of the limited size, weight, speed, operating conditions, and safety features included on the proposed aircraft within this petition. Additionally, as is highlighted in the FAA Modernization and Reform Act of 2012, the integration of UAS into the National Airspace System is inherently in the public interest so long as it can be accomplished with at least an equivalent level of safety as is currently provided by existing FAA rules and regulations.

On top of this, the utilization of sUAS in the Aerial Cinematography Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– Aerial Cinematography is an industry that requires repetitive flights. There are oft en multiple takes of the same scene in order to get the perfect shot with the perfect lighting. For this reason, the same flight has to occur several times in a short time period. This isn’t necessarily efficient for a manned aircraft because it needs to stay aloft during filming and due to this, wastes time and fuel waiting for successive shots. A UAV on the other hand can land in between shots and use significantly less power. Plus, because of the inherent risks of flying at low altitudes for manned a ircraft (structures, people, obstacles, etc.), repetitive shots require repetitive risky flight operations.

 Dangerous

– Aerial Cinematography is almost always done at very low altitudes, which is very dangerous airspace for large, manned aircraft. Ther e are more obstacles to consider at low altitudes and less margin for error. Therefore aerial cinematography flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a saferPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 53 alternative as it is more maneuverable in confined spaces and less damaging in the case of a
crash.

 Dirty

– Some aerial cinematography is extreme in nature and may include things like
airborne obstacles. Wh ile the Petitioner’s UAV system would be maintaining a safe distance from this hazardous environment and remaining within line of sight, it is important to consider that unpredictable accidents can happen in which a bird might fly into a prop as an example . In this situation it would obviously be better to have a small unmanned craft than a large, manned aircraft, carrying a pilot and flammable fuel. As was seen in the Miracle on the Hudson Incident, birds can have a devastating effect on an aircraft if t hey damage a prop or get sucked into an engine.

 Deep

– Some aerial cinematography might require capabilities that only an unmanned aircraft can perform, such as flying in extremely close proximity to structures or other obstacles at low speeds. This ty pe of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of s UAS use in the Aerial Cinematography Industry as being within the public interest.

 Exemption Numbers:

o 11540

o 11153

o 12031



### Environmental Protection

Environmental Protection and Conservation are a vital component of a healthy planet. Throughout the years many conservation efforts have been made based on environmental research captured from the air. Imaging from these elevated altitudes gives resea rchers on the ground a different vantage point which allows for more detailed information of a broader area. Much like aerial imagery experts in the Agricultural Industry, conservationists use many of the same aerial imaging techniques, including, multisp ectral imagery, visible light spectrum imagery, image stitching, 3D mapping, and more. The data sets that can be captured using these various techniques allows for researchers to develop action plans on how to best address potential environmental concerns . It is for this reason that the Petitioner seeks an exemption under Section 333 in an effort to provide services to the Conservation Industry. Clearly, the use of any aerial imagery device is helpful in the fight to protect the environment but especiall y when that device is inexpensive, efficient to operate, rapidly deployable, safe to operate, and produces a low carbon footprint.

All of these attributes are associated with the types of small unmanned aircraft utilized by the Petitioner. Due to this, it is the Petitioner’s view that the utilization of sUAS in the Conservation IndustryPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 54

is within the Public Interest, as it provides the public good of a healthier planet. Additionally, it is the
belief of the Petitioner that the use of sUAS in the Conserv ation Industry would also provide an equivalent level of safety as is provided by current rules governing manned aircraft.

For many years manned aircraft have been utilized to execute a variety of tasks in the Conservation landscape, including, taking po pulation counts of species, examining environmental disasters such as oil spills, taking multispectral imagery to observe invasive species growth, and much more. These types of applications typically require a vehicle that can fly, a couple humans to oper ate the craft and manage the sensors, and some sort of sensor payload that may include devices such as visible and multispectral cameras as an example. This is clearly a large operation and potentially a very expensive one in terms of time and money. Con sider the fact that to own or rent a manned aircraft is highly expensive for the average conservationist. Additionally, consider that many of the types of businesses that operate in this

space are non

- profits who may not have the budgets to fund a full

- sc ale flyover with an actual plane. Plus, with many of these businesses being donation

- based, their budgets may fluctuate from year to year based on the economy. This could potentially make it very difficult to perform multi

- year studies in which multiple flights over multiple years must be flown. In a good year these example non

- profits might be able to swing it but in bad years, when their donations are down, they may have difficulty funding these manned flights and therefore, may need to end the study o r move forward with incomplete data.

A small unmanned aircraft, such as the one flown by the Petitioner, avoids many of the pitfalls mentioned above relating to manned aircraft. From a monetary perspective, consider the fact that many small unmanned air craft flight services cost less than their manned equivalents , meaning a
conservationist can obtain valuable information at low cost. This is a huge advantage for the personal
conservationist or the non

- profit. Additionally, from a time standpoint, a sUA S is ra pidly deployable, meaning the Petitioner can take it out of its case and literally be imaging an area of interest in a couple minutes. This helps in many situations, but especially those situations that are fast moving. In the case
of an environme ntal disaster as an example, the Petitioner may want to capture the immediate aftermath which is likely not possible for a manned aircraft as you have to rent planes ahead of time. Also, in any situation where animals are involved, a rapidly deployable sy stem is key. This is because a species that is being target ed for imaging may be unpredicatble and the opportunity to snap a photo is very short

- lived.

From a safety standpoint as well, sUAS provide a safe means of image capture. First, a sUAS is

unman ned, meaning if there is a loss of the aircraft due to some sort of accident, only the aircraft is damaged and not the pilot and crew inside, as is the case with manned aircraft. Additionally, because the sUAS is small and battery

- powered, it poses a less er risk to people and property on the ground than does a manned aircraft that weighs thousands of pounds and carries flammable fuel. Furthermore, the type of imagery sought by the Petitioner is imagery that is relatively close to the ground (always below 400 feet AGL). This is a potentially hazardous environment for any aircraft as the chances of collision with a ground

- based object, feature, or structure are significantly increased. Due to this, it is the belief
of the Petitioner that it would be safer to have a small unmanned aircraft operating in this sort of environment as it is smaller and has superior maneuverability when compared to a manned aircraft. Finally, it should be noted that the type of small unmanned aircraft utilized by the Petitioner i s electric powered, meaning it has a lower carbon footprint than a manned aircraft.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 55

On top of this, the utilization of sUAS in the Environmental Protection/Conservation Industry falls in line with the 4D’s of UAS Intervention, which points to the Public In terest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Environmental Protection/Conservation Industry is an industry that requires repetitive flights. Often, as is the case in other industries that capture researc h

- based imagery, multiple flights must be performed of the same area with multiple sensor payloads. This could be performed by a manned aircraft, however, it may be more advantageous to utilize a UAV, especially in situations where a flight with a manned aircraft may be risky due to hazards at low

- altitudes. Although one flight in a manned aircraft over the area might be possible, multiple flights repeatedly expose that aircraft and the pilot to ground

- based threats, which over time expose the aircraft to increase d chances of an accident. This is particularly the case when it comes to manned aircraft because the chance for human error is possible. When a pilot performs the same dull flight over and over, they may get bored and overlook an obstacle they h ave previously avoided. This can cause accidents. A UAV on the other hand is a bit more automated, meaning flight routes can be preprogrammed and users have a computer backup.

 Dangerous

– Aerial Conservation Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Conservation flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash.

 Dirty

– Some Conservation Imagery is captured in potentially hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. A flock of birds for example might quickly change directions and come into contact with the aircraft. Usually this isn’t a big deal, however, larger birds, such as ducks, geese , or cranes, could significantly damage a manned aircraft by breaking a prop, damaging a window, or being sucked into an engine. Each of these situations is dangerous for the crew onboard. Therefore, it is the belief of the Petitioner that this same type of impact with a small UAV would be safer than a manned aircraft
because in t he worst case scenario there isn’t the loss of human life or significant damage to property on the ground as the sUAS weighs below ten pounds and doesn’t carry flammable
fuel.

 Deep

– Some Aerial Conservation Imaging might require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to natural features or other obstaclesPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 56 at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an u nmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Environmental Protection/Conservation Industry as being within the public interest.

 Exemption Number:

o 136 77



### Fire

The Fire Fighting and Fire Response Industries are industries in which small unmanned aircraft will play a vital role moving forward and will of fer support services. These industries are known for their rapid response times which are needed in order to save lives and property. Furthermore, the situations and environments common in these industries require constant visual observance to monitor re al

- time changes in a fire’s progression. Currently, much of this is done, especially in forestry fires, using aerial imaging from a manned aircraft flying a safe distance away. The imagery captured on these flights is vital for the successful outing of t he fire but also for the safety of the people on the ground. A fire can move quickly and change directions on a dime. Due to this it is important for firefighters on the ground to have a constant, real

- time assessment of what is happening around them. I n most cases a firefighter may not be able to see everything that is happening around them because they have an inferior vantage point on the ground as compared to the vantage point an aircraft can capture from the air.

The Petitioner seeks exemption under Section 333 in an effort to gain the right to provide services to the Fire Industry in order to help them in situations where a fire needs to be viewed from the air quickly. Where a manned aircraft may take a while to get to the scene and expose pilots t o a hazardous environment, the type of sUAS utilized by the Petitioner is rapidly deployable, meaning it can be in the air sending a real time feed to a fire captain in minutes. With that information the captain can communicate with his guys on the ground to make sure they don’t get trapped or caught in a difficult situation. This is clearly in the Public Interest as this type of technology keeps firefighters on the ground safe. Forest fires especially, are situations in which firefighters can get trappe d if they cannot see where the flames are moving in real time. Back in 2013, 19 elite firefighters were killed in Arizona battling a
forest fire that turned aroun d on them due to a wind change

. 17 Although any aircraft is difficult to fly in
a smoke

- fille d situation and the Petitioner will always maintain visual line of sight, an aerial perspective, even from a distance, can be helpful to those on the ground.

While an aerial perspective of a blaze is helpful, the Petitioner understands the value manned air craft can provide to a fire situation and will not fly the sUAS unless given permission by the proper authorities and after ensuring they will not be interfering with any manned aircraft efforts.

In addition to providing the public good of keeping firefi ghters safe, it should also be noted that the use of a small unmanned aircraft also provides a low

- cost alternative to manned aircraft. This would in turn drive down the costs to a fire department for manned aircraft surveillance and potentially help lowe r the burden on the public who fund the fire departments through taxes.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 57

Furthermore, a UAV is a safer alternative to a manned aircraft in many firefighting situations. This is the case because often these flights will happen at low altitudes where the ri sk of collision with ground

based features, obstacles, or the like are greatest. A manned aircraft is not as well suited for these flying environments because they are bigger than sUAS, they carry a crew, they are not as maneuverable, and they carry flamm able fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide value in terms of cost savings and enhanced safety.

On top of this, the utilization of sUAS in the Firefighting/Fire Response Industry fa lls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Fire Industry is an industry that requires repetitive flights. Often, especially w ith
fixed

- wing aircraft, a pilot must fly his plane over a specific area in which the blaze is occurring. Due to the fact that planes cannot effectively hover, the pilot must perform the same approach and flyover over and over again in order to keep a con stant eye on the situation. The sUAS used by the Petitioner however has the ability to hover in one spot, giving it the ability to maintain constant visual contact over the area of interest. When the pilot of a plane performs the same flight over an d ove r, they may overlook an obstacle they have previously avoided. This can cause accidents. A UAV on the other hand is a bit more automated, meaning it can hover in place and use its onboard flight controller to automatically adjust for wind and maintain it s position.

 Dangerous

– Aerial Fire Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Fire flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in t he case of a crash as it weighs significantly less and doesn’t carry a crew or flammable fuel.

 Dirty

– Most Aerial Fire Imagery is captured in hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these pot ential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. If for instance, the wind were to change direction, blowing smoke into the flight path, the pilot of a UAV has automated f ail

- safes that will bring the aircraft home automatically. A manned aircraft on the other hand is going to have to rely on a human to get it back safely.

 Deep

– Some Fire Imaging might require capabilities that only an unmanned aircraft can perform, s uch as flying in close proximity to natural features or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 58

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Fire Support Industry as being within the public interest.

 Exemption Number:

o 13677



### Insurance

Another industry that is going to see huge potential in the next couple years through the utilization of sUAS aircraft is the insurance industry. One of the reasons for this is the obvious benefit an aerial perspective can be when assessing an insurance situation, be it a car accident, crop damage, building collapse, or the like. The ability to get above the insured asset allows for a clearer perspective of the situation and provides a bird’s eye view of what happened. This allows for more accurate insurance estimates and in turn, more accurate payouts.

Using the example of crop insurance, it is clear to see the public benefit of utilizing sUAS aircraft for the purposes of insurance.

The crop insu rance industry is a big business. Every year acres of a variety of crops are insured from loss with large crop insurance agents thr oughout rural America. In situations of flooding, drought, wind events, or the like , consider the amount of d amage that can be done to a crop. If the crop is laid flat from high winds or is damaged significantly from hail, the farmer is going to experience some type of yield loss. The payout that farmer receives is going to be dependent on the extent of his yield loss as is determined by an insurance adjuster. To determine the farmer’s loss an adjuster might use a variety of strategies, including; remaining population counts, standard deviation calculations, and the like. However, when a large swath of area is damaged by a storm, insurance adjusters are spread thin trying to get accurate estimates for every field in the area. This can lead to overestimates, underestimates, and in general, incorrect or otherwise errored payouts. This can lead to losses for the insurance

com pany, losses for the farmer, and premiums that are based on payouts that may be inaccurate.

However, by utilizing sUAS aircraft, this could change, as the use of UAVs and software could allow for more efficient, automated practices. As an example, a sof tware program that can use counting programs or image recognition technology to estimate losses would be much more automated and potentially more accurate than a team of adjusters who all might have slightly different biases when making assessments. Furth ermore, the estimates and payouts as a whole across an entire insurance company would be much more consistent, as the same software is reading all the imagery captured and thus, automation allows for consistency and confidence in operations.

The crop ins urance example is just one example of how the insurance industry can benefit from the use of sUAS aircraft, however, this same principle can be see n across a variety of applications in the broader insurance industry. The public benefit of this is clear, a s having more accurate and consistent payouts makes insurance companies more efficient and thus, premiums are more accurate.

Furthermore, the insurance industry is another industry that sUAS should be used for according to the 4
D’s.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 59

 Dull

– The insuranc e industry is another industry that may require repeated flights of the

same area or on

- demand flights. Consider crop insurance. In the situation where a small pocket of a country received straight line winds, only a couple farms or even a couple farm
fi elds are actually affected. Therefore, only one or two fields may need to be flown that day. It would be much better to have a UAV in the adjuster’s vehicle so he can fly on

demand that day only where there are issues, as opposed to hiring a manned aircr aft to fly over and maybe only take a picture of one or a few fields. Furthermore, weather events may be sporadic, meaning as the adjuster goes from farm to farm, he isn’t sure if there is extensive damage or not and therefore it would be an expensive gam ble to send a plane up when there isn’t a certainty that there is extensive damage to film.

 Dangerous

– Commercial sUAS Insurance flights might also be dangerous. Consider a damaged building or structure. It may be better to fly that dangerous struct ure with a small unmanned craft just in case that structure was threatening to collapse.

 Dirty

– Consider a hazardous spill that came as a result of a derailed train or overturned
semi

- trailer. This example is an insurance event in which an adjuster i s going to want to assess the damage while avoiding a dangerous environment. Noxious fumes may be in the area and as such, the adjuster might want to fly the area with a sUAS.

 Deep

– Once again, sUAS allow for operators to capture high resolution data at low altitudes. This is true in the Insurance Industry as well and low altitude flight can be especially dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in confined areas can be impossible for man ned aircraft as their maneuverability is such that the confined area is too small for safe flight. Consider a grain facility that is damaged in a tornado. That facility should be inspected at low altitudes, but there are a variety of obstacles, such as g rain towers and cables, that would pose a threat to
a manned aircraft.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Insurance Industry as being within the public interest.

 Exemption Number s:

o 11293

o 11857



### Land Inspection

The Land Information Industry is an industry poised to gain a lot from the utilization of sUAS aircraft. The aerial p erspective these units can provide to a land surveyor or developer, is enormous. Land Information covers a broad range of land evaluation applications. One of the main applications that isPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 60

currently being used is stitched, 3D mapping, which allows for op erators to visualize a landscape in highly accurate 3D form. This allows for accuracy in the centimeter range, which can help land managers determine tile lines in agriculture, engineers develop drainage ditches for streams, planning commissions create pl at maps for new developments, and architects design new building construction.

All of these applications are in the public interest. A land manager putting in tile lines in his agricultural fields helps quell runoff and erosion issues, which leads to high er yields, a healthier environment, and less pollution in our waterways. Additionally, the engineer who is developing drainage paths and ditches based on 3D mapping from a sUAS is going to prevent large

- scale flooding, which reduces damages to surrounding communities and, in turn, lowers insurance premiums for the country as a whole. In much the same way, planning commissions creating maps and running lines into a new development helps foster community growth and ensures the right amount of infrastructure for the community. Finally, the architect designing a new building will be better able to place that building on solid ground and allow it to better fit in the surrounding landscape. This helps ensure the safety of the building while also ensuring the c ommunity looks nice.

Referring back to the 4

- D analysis of UAV use, it is clear that the Land Information Services Industry has many applications of data capture that point to the use of UAV systems over manned aircraft because;

 Dull

– Land Information Fli ghts may require a lot of repetition and/or rapid deployment of a data capture device to ensure data is captured at the right time. A government agency looking to quell runoff issues into local lakes and streams from agricultural fertilizers may

want to e xamine 3D maps and drainage maps that are captured when it is raining or after a heavy rain. The characteristics of these specific flight times will better show the results of water flowage as the flowage is happening or right after it happened. This all ows for more accurate mapping and a better idea of the real world drainage issues in an area. Having this information leads to better engineering which in turn leads to a healthier environment and community.

 Dangerous

– As the example above shows, th e rapid deployment of a sUAS in a rain storm or right after a rain storm could be dangerous for a manned aircraft. Most private pilots who would be flying to take imagery like this would want to avoid weather so as to not have
to be instrument rated or ha ve to operate in non

- visual conditions. Cloud cover may be low during these rain events as well, which may make imagery from a manned aircraft impossible to capture. However, with a sUAS operating below the clouds, you could capture this imagery so long as you have the ability to follow VFR requirements. With weather often changing in an instant, a small opening in the clouds in one area might be all you need to fly a sUAS on a mapping mission while manned aircraft is grounded due to the overall weather in the surrounding area.

 Dirty

– Land Information flights by nature may occur in hazardous environments. A lot of the 3D mapping missions conducted in this industry are done in areas of high topography,
which can be hazardous for manned aircraft at low altitudes.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 61

 Deep

– Once again, sUAS allow for operators to capture high resolution data at low altitudes. This is true in the Land Information Industry as well and low altitude flight can be especially dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in confined areas can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight.

Therefore, the promotion of the public interest descr ibed above coupled with the enhanced safety provided by sUAS flights in the Land Information Industry, strongly supports the granting of this petition.

Furthermore, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in Land Information/Management Industry as being within the public interest.

 Exemption Numbers:

o 11109

o 11204

o 11286



### Real Estate

The Real Estate Ind ustry was one of the first industries to be granted an Exemption under Section 333.
One of the reasons for this is the obvious benefit the utilization of a small unmanned aircraft can provide for the purposes of property and home sales. The ability to ga in an aerial perspective of a property or house allows potential buyers a way of seeing the property in its entirety. When thinking about traditional real estate listings, there are often a series of photographs of the house or property,
and its surroundi ngs. However, these pictures are not necessarily congruent, meaning, you, as a buyer, can’t put one picture with the next picture and get a walk around of the property.

Furthe rmore, aerial cinematography for real estate has existed for many years, however it has previously been accomplished using manned fixed

- wing or helicopter aircraft. The expense of utilizing this form of cinematography is extremely costly and prices many r ealtors and homeowners out of this form of marketing. However, this form of marketing is very valuable and wou ld likely be used by more
sellers and agents if it were available at an efficient price

. Additionally, utilizing manned aircraft to capture the type of aerial marketing possible with a sUAS poses significant threats and problems to a community. Obviously a low flying plane or helicopter would supply significant noise and annoyance among neighbors of a home being videoed from a plane or helicopter. It is for th is reason that there are noise ordinances across the country pertaining to manned aircraft. Obviously, a light

- weight sUAS will produce much less noise than a helicopter or plane operating at low altitudes. Furthermore, there is also substantially less r isk associated with a sUAS performing a low

- altitude real estate flight, especially in populated neighborhoods. This is the case because if a manned aircraft goes down in a populated neighborhood there will likely be fatalities orPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 62

significant damage to th e plane and crash site. A sUAS on the other hand would likely cause little damage in the case of a catastrophic crash. Plus, because the sUAS proposed in this petition do not carry combustible fuel, the after

- effect damage is far less as well because the re isn’t a risk of a fuel tank exploding or starting on fire.

Furthermore, when looking back at the 4D’s of UAV Use, it is clear that Real Estate photography and cinematography using small unmanned aircraft fits the 4D’s.

 Dull

– Real Estate flights for aerial cinematography are a sUAS use

- case marked by repetition
and on

- demand access. More clearly, homes may need to be flown multiple times and on

demand. The key to a good real estate video is that it nicely highlights the features of the real
estate b eing filmed and does so in good lighting conditions. Lighting conditions change constantly and it is best if you can adapt to the lighting and fly at the perfect time in the perfect weather to get the best footage. This may mean waiting for 5 or 10 minut es for a cloud to pass through. With a manned aircraft this expensive to do. Plus, with many private pilots renting their aircraft, it would be hard to anticipate what time to rent the plane in order to have it in position at the perfect time.

 Da ngerous

– Real Estate flights using manned aircraft would be highly dangerous in comparison to unmanned aircraft. The reason for this is because most flights take place low to the ground, right above houses and many times above highly populated neighborho ods. An accident with a manned aircraft in these conditions could be catastrophic, with potentially many casualties and a lot of property damage. An unmanned craft, like the ones described in this petition, would cause much less damage in the case of an accident, as they are small, battery powered, and weigh under 10 lbs.

 Dirty

– Commercial UAV flights in the real estate industry can also be dirty, in that they can take place in potentially hazardous environments. Commercial real estate in particul ar, in which large factories or plants may be being sold, could pose hazardous environments that are best filmed by sUAS aircraft so as to not expose humans to hazardous waste, gases, or materials for example. Furthermore, decrepit or abandoned buildings that are dangerous to walk through or near, may be best flown using an unmanned aircraft.

 Deep

– Once again, sUAS allow for operators to capture high resolution data at low altitudes. This is true in the Real Estate Industry as well and low altitude fli ght can be especially dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in confined areas, such as in neighborhoods as an example, can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight.

Finally, because the proposed sUAS contained in this Petition are battery

- powered, they do not release environmentally hazardous emissions. Thus, utilizing these micro

- UAVs in place of manned aircra ft benefits the public by promoting a healthier environment.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 63

By granting this Petition for Exemption and allowing commercial sUAS flights in the Real Estate Industry, the FAA will be contributing to economic growth by supporting the housing industry and commercial real estate industry, thereby strengthening the economy. Furthermore, all of this can be done by maintaining the safety of the National Airspace and people & property on the ground.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Real Estate Industry as being within the public interest.

 Exemption Numbers:

o 11062

o 11109

o 11112

o 11213

o 11364



### Search and Rescue

The Search and Rescue Industry is an industry in which small unmanned aircraft will play a vital role moving forward. This industry is known for its rapid response times which are needed in order to save
lives. Further more, the situations and environments common in this industry require documented visual observance over broad areas. Currently, much of this is done using aerial imaging from a manned aircraft. The imagery captured on these flights is vital not only when it comes to finding lost people but also in documenting areas that have already been searched. In a searching effort this is important because searchers don’t want to waste time looking in areas that have already been searched. Utilizing
a UAV allows f or searchers to get an aerial vantage point as well as document areas that have been searched accurately. For instance, a search crew could map the areas of interest using their UAV, stitching the images they get from the camera and have a georeferenced m ap of the area in question. In most cases this map is laid over Google Earth and can clearly mark an area that has already been searched. Additionally, because the map is georeferenced, the user can pinpoint locations or objects of interest and pull a la titude and longitude for a more detailed search. This is a highly valuable attribute of stitched imagery from a UAV.

In addition, a UAV can provide a superior vantage point for searchers operating on the ground. The UAV utilized by the Petitioner offers long

- range, high definition FPV which can be used by a team leader to relay to his ground searchers where to move next and if he sees anything of interest from the air.

The Petitioner seeks exemption under Section 333 in an effort to gain the right to p rovide services to the Search and Rescue Industry in order to help in situations where a visual inspection from the air is necessary. The Petitioner seeks this exemption because they believe the use of unmanned aircraft in this industry will provide a pub lic good while maintaining the safety of the National Airspace System.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 64

The Petitioner’s UAV is rapidly deployable meaning it can help in time

- sensitive rescue efforts. Additionally, with its ability to take high definition video and pictures while geore ferencing all of its images, the Petitioner’s UAV can be a valuable asset to a Search and Rescue Team. Plus, with the aerial perspective this type of UAV can provide, the chances of finding a lost or periled individual increase. Clearly, finding and savi ng lost people is a public good and one that can be bolstered through the use of

a UAV.

Furthermore, utilizing a UAV for this type of work is a safer alternative when compared to manned aircraft. This is the case because often these flights will happen at low altitudes where the risk of collision with ground

- based features, obstacles, or the like are greatest. A manned aircraft is not as well suited for these flying environments because they are bigger than sUAS, they carry a crew, they are not

as mane uverable, and they carry flammable fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide value in terms of cost savings and enhanced safety to the Search and Rescue Industry.

On top of this, the utilization of sUAS in the Search and Rescue Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Search and Rescue Industry is an industry that requires dull flights. Often, especially
with fixed

- wing aircraft, a pilot must fly his plane over a specific area of interest in a very specific and straight line pattern. This is to ensure complete coverage of the search zone. Thi s causes the pilot to fly the same straight line routes, one next to the other, over and over. The
“dullness” of this type of flight may cause accidents due to a pi lot overlooking a feature they had previously avoided . The sUAS used by the Petitioner however

, has the ability to util ize preprogrammed flight routes, which can automate the process and allow for safer operations.

 Dangerous

– Aerial Search and Rescue Imagery is often captured at low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Search and Rescue flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash as it weighs significantly less and doesn’t carry a crew or flammable fuel.

 Dirty

– Aerial Search and Rescue Imagery is som etimes captured in hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situat ions. For instance, if a UAV is being used to provide a live

- feed view of a rescue situation, there may be a host of unpredictable hazards such as rock

- falls, crashing waves, avalanches, or the like. In each of these situations it would be better to have an expendable UAV system rather than a manned aircraft with lives onboard.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 65

 Deep

– Some Search and Rescue imaging may require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to natural features or other obst acles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Additionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Search and Rescue Industry as being within the public interest.

 Exemption Number:

o 11419


## Regulations Requested for Exemption

Appendix 1: Regulations Requested f or Exemption

– List

https://drive.google.com/file/d/0B8sknt2zpxhMajc4dHA2bjE4bjg/view?usp=sharing



## Exhibit List

Exhibit 1: Michael Frey Operations Manual

https://drive.google.com/file/d/0B8sknt2zpxhMUDZuZTNzLTRpUkE/view?usp=sharing



### Exhibit 2: Michael Frey Logbook Example

Below is a logbook example from the app that is running the Flight Logs for the Petitioner’s aircraft. The specific flight logs pictured are just an example and not specific to the Petitioner’s prior flights. In addition to the logbook , please see the linked video ( https://www.youtube.com/watch?v=4afE

- rd6xoY ) that shows how the flight logs can be played back utilizing the same logging app for each flight.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 66



### Exhibit 3: Michael Frey Visual Observer Training Procedures & Guide

Visual Observer Training Procedures

https://drive.google.com/file/d/0B8sknt2zpxhM NFllQVJZdHVsQ0E/view?usp=sharing



### Visual Observer Training Guide

https://drive.google.com/file/d/0B8sknt2zpxhMbElBZTcwUi02aHM/view?usp=sharing



### Exhibit 4: Michael Frey Pilot In Command Training Guide

Pilot In Command Training Procedures

https://drive.google.com/file/d/0B8sknt2zpxhMNFl lQVJZdHVsQ0E/view?usp=sharing



### Pilot in Command Training Guide

https://drive.google.com/file/d/0B8sknt2zpxhMREF0OHZLZ25Jc2M/view?usp=sharingPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 67



### Exhibit 5: DJI Phantom 3 Professional

http://www.dji.com/product/phantom

- 3



### Exhibit 6: DJI Phantom 3 Professional User Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf



### Exhibit 7: DJI Phantom 3 Professional Quick Start Guide

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en.pdf



### Exhibit 8: DJI Phantom 3 Professional Features

http://www.dji.com/product/phantom

- 3/feature



### Exhibit 9: DJI Phantom 3 Professional Specifications

http://www.dji.com/product/phantom

- 3/spec



### Exhibit 1 0: DJI Phantom 3 Pr ofessional Flight Controller System

http://www.dji.com/product/phantom

- 3/flight

- system



### Exhibit 1 1: DJI Phantom 3 Professional Smart Battery Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdfPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 68



### Exhibit 1 2: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

http://download.dji

- innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf



### Ex hibit 1 3: DJ I Inspire 1

http://www.dji.com/product/inspire

- 1



### Exhibit 1 4: DJI Inspire 1 User Manual

htt p://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf



### Exhibit 1 5: DJI Inspire 1 Quick Start Guide

http://dow nload.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_en.pdf



### Exhibit 1 6: DJI Inspire 1 Features

http://www.dji.com/product/inspire

- 1/feature



### Exhibit 1 7: DJI Inspire 1 Specifications

http://www.dji.com/product/inspire

- 1/spec



### Exhibit 1 8: DJI Inspire 1 Flight Controller System

http://www.dji.com/ product/inspire

- 1/flight

- control



### Exhibit 1 9: DJI Inspire 1 Smart Battery ManualPETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 69

http://download.dji

innovations.com/downloads/i nspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 2 0: DJI Matrice 100

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100



### Exhibit 2 1: DJI Matric e 100 User Manual

http://download.dji

- innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf



### Exhibit 21 : DJI Matrice 100 Features

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/features



### Exhibit 22 : DJI Matrice 100 Specifications

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/specs



### Exhibit 23 : DJI Matrice 100 Smart Battery Manual

http://download.dji

innovations.com/downloads/dev/Matrice/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 24: Immersion Vortex 250 Pro

http://www.immers ionrc.com/fpv

- products/vortex

- 250

- pro/



### Exhibit 25: Immersion Vortex 250 Pro User Manual

https://docs.google.com/document/d/ 1w_OghmdFwrRWjZCubv5BW6PUvECgJO1FyiUbRPlx_W0/edit?pl i=1#heading=h.bvt9t4t8twn2PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 70



### Exhibit 26: Immersion Vortex 250 Pro Quick Start Guide

https://docs.google.com/document/d/1w_OghmdFwrRWjZCubv5BW6PUvECgJO1FyiUbRPlx_W0/edit?pl i=1#heading=h.bvt9t4t8twn2



### Exhibit 27: Immersion Vortex 250 Pro Features

http://www .immersionrc.com/fpv

- products/vortex

- 250

- pro/



### Exhibit 28: Immersion Vortex 250 Pro Specifications

Weight: ~415g without battery, or HD camera

Power Requirements: 3s

- 4s LiPo (typical)

ESCs: Full Custom, 20A cont. 22A peak, rotorSENSE, OneShot125

Moto rs: Custom V

- Spec 2204

- 2300kV, with 3mm axles, 5mm shafts

Props: OEM Gemfan 5045 GF Blunt

- Nose

Flight Camera: FatShark 700TVL v2 CMOS (included)

HD Camera: GoPro Hero, Hero 3⁄4

Receiver Compatibility: CPPM, S

- Bus, SpektrumTM , XBus, SumH, SumD



### Exhibit 29: Immersion Vortex 250 Pro Flight Controller System

Fusion Gen2 Flight Controller

– The ImmersionRC Fusion, a highly integrated state

- of

- the

- art flight controller, gets an extensive update for the Vortex 250. The “F1” class processor is updated to an F3, flash memory for BlackBox log storage is integrated, the buzzer is replaced with one MUCH louder, and a port is added for direct serial receiver hookup (5V and 3.3V supply options). As for the Fusion Gen1, the Gen2 is preloaded with a custom build of Clea nFlight, and is future

- proof, supporting future updates.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 71

The high performance “F3” processor provides > 2x the performance of its predecessor, allowing lower loop times, and better flight performance. PIDs are adjusted on

- screen, in easy

- to

- use menus, d riven directly from the R/C Tx.



### Exhibit 30 : TILT Pro

http://www.tiltdrone.com/



### Exhi bit 31 : TILT Pro Features

http://www.tiltdrone.com/



### Exhibit 32 : TILT Pro Specifica tions

Tilting arms mechanism and electronics : aluminum pulleys, PUR timing belt with steel wires and 14 gr, 2.6 kg torque, metal gear servo motor

Dynamic tilting arms system implemented in Cleanflight

Tilting system calibration and setup via Cleanflight c onfigurator

Motor

- to

- motor distance: 330 mm

Accepts any motors with up to 16×19 mm attachment points

Battery tray system that avoids balancing the quadcopter every time you change the battery, even if they are of different weight

Over 370 square centimeter s to place your gear and battery, the largest real estate in the market compared with even bigger multirotors sizes

Several 3D printing files available on Thingiverse from en d of May 2015 (user: The_Tilt_Drone_Racer)

Download the released 3D printing files and print spares on your own printer or 3D printing hub

Power Distribution Board (PDB) rated at 120 A continuous current and 6S capable (optional)PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 72



### E xhibit 33 : TILT Pro Fligh t Controller System

http://www.tiltdrone.com/



## References

1.) 

### NTSB. Michael P. Huerta, Administrator, Federal Aviation Administration v. Raphael

Pirker . Washington, DC: National Transportation Safety Board, 17 Nov. 2014.
PDF. Aircraft Definition.

2.) 

### Administration, Federal Aviation. "FAA Streamlines UAS COAs for Section 333." FAA.gov

.

Federal Aviation Administration, 24 Mar. 2015. Web. 5 Nov. 2015.

3.) 

### Administration, Federal Aviation. "Section 333 Petition Guidance & Che cklist." (n.d.): n.

pag. FAA.gov . Federal Aviation Administration. Web. Conditions for a successful Exemption.

4.) 

### Watts, Adam C., Vincent G. Ambrosia, and Everett A. Hinkley. Unmanned Aircraft

Systems in Remote Sensing and Scientific Research: Classification and Consideration of Use . Basel, Switzerland:

w ww.mdpi.com/journal/remotesensing, 8 June 2012. PDF. "D's" of Unmanned
Aircraft Use.

5.) 

### SKYbrary. "Unmanned Aircraft Systems."

- SKYbrary Aviation Safety. N.p., n.d. Web.

20 July 2015.

6.) 

### Administration, Federal Aviation. "Public Guidance for Petitions for Exemption under

Section 333." FAA.gov . Federal Av iation Administration, n.d. Web.

7.) 

### "FAA Summary Grants Speed UAS Exemptions." FAA Summary Grants Speed UAS

Exemptions. Federal Aviation Administration, n.d. Web. 2 0 July 2015. Permitting Recreational and Sport Pilot Certificates.

8.) 

### FAR Part 91

- Basic VFR Weather Minimums, Code of Federal Regulations § 91.155

(2004). Print.

9.) 

### Administration, Transportation Security. "Vetting of Airmen Certificates and General

Aviatio n Airport Access and Security Procedures." Department of Homeland Security . Office of Inspector General, 7 July 2011. Web. 5 Nov. 2015.PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 73

10.) 

### MacPherson, Rebecca B. "U.S. DOT / FAA

- Office of the Chief Counsel." Letter to Mr.

Timothy John Gilbert. 25 Feb. 201 1. MS. 800 Independence Ave. S.W., Washington, DC, Maryland. Clarification on "Furtherance of a business."

11.) 

### Federal Aviation Administration . "Exemption No. 11062A Regulatory Docket No. FAA

2014

- 0352." Department of T ransportation, 23 July 2015. PDF

.

12.) 

### Je nsen, Warren, PhD. Ground

- Based Visual Observer/Crewmember Training for UAS

.

New York, NY: Slideserve.com, 9 July 2008. PPT. Visual Observer and Pilot In Command Training Guidance and Format.

13.) 

### Schoepp, Brenda. "Brenda Schoepp

- International Mentor. Inspi rational Speaker.

Creative Writer." Brenda Schoepp. Brenda Schoepp, 2012. Web. 20 July 2015. Quote.

14.) 

### Organization, Food And Agricultural. Global Agriculture Towards 2050 . Rome, Italy:

Agricultural Development Economics Division, 13 Oct. 2009. PDF. UN Pro jections Global Food Demand in 2050.

15.) 

### “University of Wisconsin

– Whitewater 2014 Annual Report.” Enactus Scouting

Forward. Whitewater, WI: UW

- Whitewater Enactus, Feb. 2014. PRINT.

16.) 

### "Olympic Medalists among 10 Dead as Reality TV Choppers Collide." NBC News . NBC,

n.d. Web. 20 July 2015.

17.) 

### “19 Elite Firefighters Killed in Arizona Blaze; ‘Our Entire Crew was Lost’

– CNN.com.”

CNN. Cable News Network, 2 July 2013. Web. 27 Nov. 2015.


## Exemption References

Exemption # 11467

Exemption # 11905

Exemption # 1179 7

Exemption # 12031

Exemption # 11865

Exemption # 11364

Exemption # 11587

Exemption # 11857PETITIONER

- Michael Frey DOCUMENT PREPARER

– DMZ Marketing, LLC. 74



### Exemption # 11293

Exemption # 11814

Exemption # 11540

Exemption # 11345