Matthew Robert Pearce May 27, 2015

267 Golf Club Dr.

Key West, FL 33040

mattrobertpearce@gmail.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 1) Inspire Inspire 1 Quick Start Guide (EN) v1.2

2) Inspire 1 User Manual (EN) v1.2

3) Inspire 1 Maintenance Manual v1.0

4) Q500 TYPHOON INSTRUCTION MANUAL V2.1

5) Q500 TYPHOON QUICK START GUIDE V2.1

6) Q500 TYPHOON USER MANUAL V1

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA­2014­0481 in

the matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in

the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA­2014­0355 in

the matter of the petition of FLYING CAM INC
Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption

under section 333 of the FAA Modernization and Reform Act of 2012, I Matthew Robert

Pearce, referred to hereafter as the petitioner, request exemption from the following

sections of Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

(a)(1); 91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial data

collection and other flight operations that could be performed safely and more cost

effectively with the use of small UAS at low altitude within the U.S. national airspace

system as compared to a manned aircraft. Operations will be performed only at the

request of and with the authorization and permission of clients or their authorized

agents in order to facilitate commerce and raise awareness of the beneficial uses of

small unmanned air systems. So long as such operations are conducted within and

under the conditions outlined herein or as may be established by the FAA as required

by Section 333. The conditions identified and proposed by the petitioner are drawn from

references 1­3.

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;

61.113(a) & (b); The petitioner requests relief in order to facilitate the

utilization of pilots, who hold a SPORT PILOT (or greater) certificate. Any pilots

operating under this exemption would be required to comply with any conditions as set

forth and in a similar fashion to the previously granted exemptions.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU),

operations conducted closer than 500 feet to the ground may require that the UA be

operated closer than 500 feet to essential persons, or objects that would not be possible

without additional relief. The petitioner requests modification, waiver or exemption and

clarification concerning the terms “congested areas” and “densely populated”. The

petitioner requests waiver for this condition to allow reasonable and responsible

operations in areas of subdivisions and neighborhoods if required.
91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is

inapplicable since the UAS does not have an altimeter and instead utilizes electronic

GPS with a barometric sensor for altitude information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION

SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less

than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In

addition, similar UAS­specific relief has been granted in Exemption Nos. 8811, 10808,

and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in

percent to the PIC. The UA batteries provide approximately 25 minutes of powered

flight. Information provided in the operating documents discusses procedures regarding

remaining battery power management. Those documents contain a condition in which

the PIC will initiate a landing procedure when battery remaining reaches a specified

level. Given the limitations on proposed operations and the location of those proposed

operations, The FAA found that a reduced minimum power reserve for flight in daytime

VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in

Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and

ensure that the UAS is in a condition for safe flight in accordance with the operating

documents. The FAA found that adherence to the petitioner’s operating documents and

the conditions and limitations specified, describing the requirements for maintenance,

inspection, and recordkeeping, were sufficient to ensure that safety would not be

adversely affected.

The UAS

The DJI Inspire 1 and Yuneeq Q500 Typhoon are both highly successful

consumer grade small rotorcraft in the quadcopter configuration with an advertised

weight of 6.4 pounds for the Inspire 1 and 40 Ounces for the Typhoon. Top speed for

both is less than 87 knots (100 miles per hour). Both are designed primarily to carry

aloft a high definition camera. Both utilize an internal inertial measuring unit (IMU) with

integrated barometric sensor augmented with global positioning system (GPS) to

maintain its geo­spatial orientation and position. They are controlled primarily through

an FCC certified radio control (RC) unit. Real time video and telemetry information is

transmitted back to a ground control station allowing the operator and/or PIC to monitor

battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery,

and control camera angle. It has failsafe modes of operation for either loss of RC or
GPS signal. Altitude can be limited by the onboard flight controller and maximum

altitude can be preprogrammed by the PIC. Battery life limits flight times to

approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry

and external lighting cues before reaching a low battery state. An automatic termination

of flight and landing will be initiated when the battery reaches a predetermined low

state. It is anticipated that flights will usually last less than 10 minutes. More information

is available in the attachments

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1­3 Conditions and

Limitations section and believes that the procedures specified therein are reasonable

and will be utilized in order to manage and mitigate risk and ensure public safety. A

preflight checklist will be developed and employed to ensure that the UA airworthiness

will be verified before launch. Airworthiness will be maintained by performance of

routine inspections before each flight, maintaining flight and maintenance logs to record

time on failure­prone components.

The petitioner request that in a manner similar to reference 3, he be allowed to

operate within 5 miles of an airport provided that;

“The UA may not operate in Class B, C, or D airspace without

written approval from the FAA. The UA may not operate within 5 nautical

miles of the geographic center of a non­towered airport as denoted on a

current FAA­published aeronautical chart unless​a letter of agreement

with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s

COA. The letter of agreement with the airport management must be made

available to the Administrator upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner

is requesting a mechanism to facilitate such activities without requesting a new and

separate exemption(s) should the need arise. Operations within class B airspace are

not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned aircraft
of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS

in order to facilitate commerce could lead to economic growth. Operations for this

petition will enable service for property owners or their designees seeking an enhanced

perspective for characteristics, amenities, and benefits of their desired photographic

subjects that cannot be displayed through ground level videography/photography. Aerial

photography is a valuable marketing tool that can lead to increased commerce and

enhance personal photography. The petitioner will provide clients with photographic

data for these purposes on a ‘for hire’ basis. A visual observer will be utilized. Liability

insurance will be obtained commensurate with the granting of this request for

exemption. Flight data including UA flight time, Control Unit operation time, incident,

accident, and details concerning any deviations from normal operations will be available

to FAA for use in collecting data regarding the use of UAS as part of this application.

This data may be submitted to FAA via traditional means, e.g. COA Monthly Reports, or

other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial data

collection”. The reason for such a general and broad based request is that the petitioner

wishes to utilize a business strategy of horizontal integration and maximize economies

of scope in order to capitalize on opportunities as they may arise in the future without

the long turnaround time associated with additional exemptions. The petitioner's

business model is based on the idea of offering ad hoc small UAS services to

individuals or companies who wish to employ these services as a safe, effective, and

legal option to enhance their business or hobby. The petitioner’s own market research

shows pent up demand for these services currently exists. A quick internet search will

show that many are currently operating similar UAS in exactly this fashion without, it is

assumed, FAA authorization. The petitioner has refrained from engaging in commercial

use of the UAS. The primary purpose of seeking this exemption is to obtain the

capability to offer those services while remaining in compliance. The petitioner has

numerous years of experience in general, military, and commercial aviation and holds

an airman certificate, AIRLINE TRANSPORT PILOT, as well as current FAA and

military medical certificates.

Respectfully submitted,

Matthew Robert Pearce