U.S. Department of Transportation 10/9/2015

Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590

**Re:** Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam, This petition is being submitted on our own behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Stout Aerial ( SA ), a Kentucky based Veteran ow ned small business operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography/video, survey for various industries, and Search and Rescue operations hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption wou ld permit Stout Aerial to pursue its commercial interests in providing services to consumers interested aerial data capture using a small advanced sUAS in the following areas: • Agricultural Surveying

• s UAS Operator Training • Real Estate Photography • Product Demonstrations • Research and Development
SA states that all sUAS flights that will occur over private or controlled access property will do so with the property owner's prior consent and knowl edge and that only people who have consented or otherwise have agreed to be in the area where photography and videography will take place will be captured. Additionally, observers who are not qualified pilots, will be trained by SA pilots to understand the proper roles of an observer, communication procedures, proper visual scan techniques, operations at non

towered airports, and appropriate sections of the Aeronautical Information Manual. Regulations from which the exemption is requested:
14 C.F. R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R . 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)Unmanned Aircraft System

sUAS are a feasible method to obtain information of agricultural cropland to determine optimum inputs that result in cost savings to farmers, yield security, and reduce environmental impact of excess fertilizers an d chemicals in the soil. We are petitioning for exemption to enable SA to operate a DJI Inspire 1 multi

- rotor equipped with a three

- axis gimbaled camera. This sUAS weighs less than 25 lbs. , have a built

- in capability to limit the height it flies above t he ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has the failsafe function of the autopilot system, which means when the communicat ion between the Main Controller and the transmitter is lost, the system will automatically trigger Return to Home and will land safely. The above specifications meet standards listed below, some derived in accordance with the Model Aircraft Operating Sta ndards: • The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the operators’ manual. Such operations wi ll insure that the sUAS will "not create a hazard to users of the national airspace system or the public." • When flying sUAV within 3 miles of an airport, airport operators will be notified and the operator will give the right of way to avoid flying in t he proximity of full

- scale aircraft. • Maximum flight time for each operational flight will be 60 minutes.

• Flights will be terminated at 20 % battery power reserve should that occur prior to the 60 minute limit. • The sUAV will be programmed so that it will not be operated at an altitude of no more than 600 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. • Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer. • The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). • The sUAS will operate at speeds of no more than 55 knots. • Given the small size of the sUAS and the restricted sterile environment within which they will operate, our sUAS operations adhere to the Reform Act's safety requirements. Additionally, as aviation enthusiasts; we have a high regard to safe operations with an understanding of FARs, pre

-flight inspections, maintenance and repair, operations within airspace, as well as being trained to high safety standards. Under the requested exemption SA ensures that all operators have completed a small unmanned aircraft systems (UAS) education and training program including all applica ble regulations and guidance documents; including aeronautical background information such as charts, NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; BasicSmall UAS Aerodynamics; Weather factors; Airmanship and Decision

- making and Safe Operating

Procedures. We respectfully request exemption under Section 333 to enable SA to operate safe, low

- risk commercial sUAV operations for the activities stated. SA at all times will respect the space and pri vacy of citizens and property whilst keeping our skies safe. Sincerely //E

-Signature// David Stout Stout Aerial 115 Double Court, Vine Grove Kentucky 40175 (270) 872

- 6268