## Petition for Exemption Filed Under Section 333

Petitioner:

Ethan Perdue

616 Scottwoods Dr.

Auburn, AL 36830 (334) 663-4541



### Objective:

The objective of this petition is to seek FAA exemption to Title 14 of Code of Federal Regulations, Part 21, Subpart H, 45.23(b) 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119(c), 91.121, 91.151(a)(1), 91.203 (a)&(b), 91.405(a), 91.407(a)(l), 91.409(a)(l)&(2), 91.417(a)&(b)

.



### Summary:

I, Ethan R. Perdue, the petitioner request exemptions in order to operate a DJI Inspire 1 Unmanned Aircraft System (UAS) within the National Airspace System. This is done in pursuant to Section 333 of the Federal Aviation Administration Modernization and Reform Act (FMRA) of 2012. The purpose of this exemption is to allow Ethan R. Perdue to operate a UAS for the purpose of aerial photography and videography, primarily for real estate, surveying, landscaping, construction, and agricultural purposes.

The owner has UAS flight experience since June, 2015 with no incidents of financial loss to property and no instances of harm to the general public including a complete absence of “near misses.” Until the approval of this exemption, the owner is strictly experienced as a hobbits of UAS flight.

Currently, the petitioner has taken steps to obtain the necessary licensing to fly a UAS for a commercial purpose. The petitioner is aware of this necessary step in order to fly for commercial purposes. Though this necessary step is not fully complete, it is noteworthy that the differences between the UAS system and small aircraft are quite different. However, it is noted that a knowledge of the available airspace between the two should be obtained for the sake of public safety. Therefore, the petitioner will not allow the UAS to be piloted for commercial purposes unless the controls are manned by a pilot with an appropriate license.



### Business Description/Public Interest:

Ethan R. Perdue (hereafter referred to as “the petitioner ”) plans to offer contract aerial photography and videography for purposes for real estate, surveying, landscaping, and agricultural purposes. The nature of the images produced will be either utilitarian, entertaining,

or both. The purposes of the petitioner ’s UAS operation is to provide quality video and photo imagery for the flowing:! ! -Aerial video and images of potential real estate sales-Aerial video and images of land sales -Aerial video and images of landmarks -Aerial video and images of building construction -Aerial video and images pertaining to land surveys -Aerial video and images of crops -Aerial video and images of livestock -Aerial video and images of land with stationary objects.

The petitioner will use a DJI Inspire 1 UAS as the flying object. This particular model has key features that enhance safety during flying. These features include:! ! -GPS and GLONASS

-Visual sensors -Live first-person view at the pilot controls -Flight termination and return to home features -Advanced power management system -Flight telemetry (altitude, speed, distance) -Built-in no-fly zones -High definition graphic output

Exact specifications of the aircraft are as follows: -Make/model: DJI Inspire 1 T600

-Class: Rotocraft -UA max takeoff weight: 6.47 pounds -Category: Land -Engine manufacturer: DJI -Engine model designation: DJI 3510 -Number of engines: 4 -Engine power output: 14 lbs. max thrust -Engine type: electric



### Regulatory Relief Requests and Reasoning:

Part 21, Subpart H The operated UAS will not carry pilots, passengers, explosive materials, or flammable materials. Due to the size, speed, range, and weight of the UAS, I request an exemption. The restricted environment and conditions of use will be as safe or safer than a conventional aircraft operating

with an airworthiness certificate without said restrictions.

45.23(b) The size of the UAS does not allow the option of a cockpit, cabin, or pilot station that would allow the use of particular words and phrases. Lettering would be difficult or impossible to place on an aircraft of such a small scale and would force the lettering to be under the size for the required minimum. The aircraft will be marked with an assigned number on the crafts exterior fuselage.

91.7(a) Since there will be no airworthiness certificate for this aircraft, provided this exemption becomes granted, no FAA regulatory standard will exist for determining airworthiness. However, thepetitioner of the UAS will ensure proper airworthiness through preflight checks and based upon the manufacturers operations manual

91.9(b)(2) The small size of the aircraft does not allow the ability to carry a flight manual on the aircraft. In lieu of this, a proper manual will be available at the ground location where the petitioner will have immediate access to the required document.

91.103 Because FAA approved flight manuals will not be available for the aircraft, an exemption will be required. Typical procedures, such as reviewing weather patterns, flight power requirements, takeoff and landing distances, along with all information found within the attached document (Inspire 1- User Manual). Equivalent levels of safety will be available due to the preflight protocol to properly match the machine.

91.109 The UAS does not have the availability of fully functional dual controls. Flight control is achieved by using a radio transmission control device. An equivalent set of controls is not provided because no pilots or passengers will be carried in the aircraft.

91.119(c) The petitioner will not fly the UAS higher than 400” above ground level and will keep the aircraft within a line-of-sight over developed and developing residential areas that may be considered congested areas. Most often, this will not be the case. Most often, the petitioner will be providing a property survey flight over empty lots or acreages with little or no structures. This minimizes the amount of bystanders in the surrounding area. In the case of flying over or near existing private property while providing residential and commercial marketing material, construction process updates, or property inspections, the landowner and nearby residents will be notified in person at the site, via telephone before the flight, through cards left behind by the petitioner, or through signage created by the petitioner. The petitioner and property owners will review the risks to property and bystanders. The small size of the UAS does not present the same level of risk as a manned aircraft performing similar duties.

91.121 The UAS does not have a barometric altimeter, but relies on GPS among other electronics to determine altitude. In addition, the UAS has built in safeguards that ensure the craft does not fly above 400’ above ground level.

91.151(a)(1) Built in safeguards provide the petitioner with a low battery warning and automatically returns the aircraft to the launch point or petitioner location. Upon the first low battery alert, the petitioner makes steps to return the UAS to a ground position. During the second warning, and automatic pilot feature lands the craft. Flights will be performed during the daylight hours and

will be done in an unobtrusive manner.

91.203 (a)&(b) Due to the size and configuration of the aircraft, there will be no ability to carry certification and registration documents on the aircraft itself. Similarly to the pilot’s manual, the necessary registration and certification documents will be located at the petitioner location.91.405(a) The petitioner will inspect the status of the aircraft prior to each flight to ensure it is an airworthy condition. These precautions can be found within the aircraft’s user manual.

91.407(a)(l) The petitioner will accept responsibly for the operational safety of the UAS, and will follow the manufacturer’s guidelines for maintenance and repair. This includes the usage of first-party replacement parts.

91.409(a)(l) &(2) The petitioner will follow the manufacturer’s guidelines to ensure that the UAS is in a condition that is safe for flight.

91.417(a)&(b) The petitioner will keep a record of all repairs and modifications at the same location as the manual, registration information, and certification information.



### Public Safety:

*Please see attachment “Inspire 1 User Manual” for safety precautions and steps taken before each flight.

In addition, I (the petitioner ) do not operate within no-fly zones centered around airports or other no-fly areas. If I must pilot within the no-fly zone of an airport, I shall contact the flight controller or airport manager for flight permission. I make landing approaches at the first instance of a low power warning. I pilot the UAS within a line-of-sight. The UAS features a GPS and return to home feature should radio contact be lost with the aircraft. The aircraft will be updated with the latest firmware available within 24 hours of takeoff. I conduct an extensive pre-flight protocol which carried safety as the highest priority. Permission is granted before all flights. Flight abort shall commence in the event of a safety breach.



### Privacy:

Operation of this UAS involves the collection of video and images that have the potential to contain the images of bystanders. The operation of this UAS will occur over public lands where operation is legal, or over private lands where the petitioner has permission to fly. At the height of craft useable operation, it is highly unlikely that an individual will be recognizable in the collected images. the absence of a zoom feature on the attached camera ensures that bystanders will retain their privacy. By law, bystanders have no expectation of privacy if filming is done over public land. Regardless, the primary goal of the petitioner ’s operation mostly revolves around stationary, non-living objects, and will allow users to have a reasonable expectation of privacy.



### Conclusion:

Thank you for your time and attention.