# Green Bee UAV

May 11, 2015

Docket Operations, M

- 30 U.S. Department of Transportation 1200 New Jersey Avenue, SE Room W12

- 140, West Ground Floor Washington, DC 20590

- 0001
Subject: Section 333 Petition for Exemption
I, Jared Nelson, of 539 Wright St #107 Denver, Colorado 80228 am petitioning the FAA for an exemption from sections 49 USC of Federal Aviation Regulations. I personally will be the sole PIC of all aerial photography, following the approval of this request

.
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 112

- 95, I am requesting certain exemptions in order to conduct residential and commercial aerial photography using a lightweight UAS’s. (DJI Phantom)

Jared Nelson 539 Wright St #107 Lakewood, CO 80228 720

- 289

- 8494 greenbee@greenbeeuav.comSummation :

I, Jared Nelson, am hereby petition ing the FAA for an exemption from various sections of 49 USC of Federal Aviation Regulations. I am a registered rotorwing pilot , and will be the Pilot in Charge of any aerial photography, following approval of this request. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 112

- 95, I request certain exemptions in order to conduct residential and commercial aerial photography) using a small Unmanned Aircraft System

- the DJI Phantom line of aircraft. The aircraft consists of four de motors with rotors, powered by a Lithium battery and managed by an on board flight control system that is remotely accessed by the Pilot in Charge using a portable control unit. The remote control unit is a wireless communication device using the 5.8GH z frequency band. Real

time viewing of the on board camera is enabled through a Wi

- Fi video link within the 2.4GHz frequency band. Both frequencies are approved by the FCC for limited

- range communication purposes. The Phantom has a maximum payload of less than three pounds including the camera, has a maximum forward speed of 29.16 knots, and is managed by a sophisticated GPS control system that has a Return To Home (RTH) procedure in the event of Loss of Signal (LOS). That same system can set maximum height and distance so the UA does not exceed preferred parameters. In addition, the control system has a No Fly Zone feature that will prevent takeoff from within Controlled/Restricted Airspace and warn the PIC of an impending intrusion when in flight. The manu facturer, DJI, regularly updates software and firmware. The latest versions, including the addition of the Washington, DC area No

- Fly Zones, have been updated to include a 25km radius in Washington, DC.
Green Bee will not use the UAS later than Civil Twil ight while doing Real Estate marketing for Realtors showing views of properties currently unattainable by still or aviation photography, at a greatly reduced cost, and much higher safety standard. We will work with local nonprofits to enhance their missi ons - including, but not limited to, historical home renovations in the Portland, OR area. I will always operate the Phantom in a safe manner, using the following pre

- flight check list and operating procedures to determine that the aircraft is physically an d electronically ready for safe flight and that permission from the property owner/representative is received: Pre

- flight Checklist: • If required, notify the Flight Standards District Office of our launch schedule and location. • Survey the property for hazards

- trees, utility poles, weather conditions, and other elements that might compromise the flight, then make a judgment as to whether to proceed. • Check the weather for wind speed, cloud cover and any forecast changes that might adversely affect fl ight safety and performance. • Examine the aircraft

- looking at connections and searching for cracks and loose parts. • Determine that the electronic elements are performing correctly (receiving more than 6 GPS signals along with calibration of the magne tic compass) • Following takeoff, within close proximity check to make sure the flight controls, engines, point of view camera, and GPS are working properly • Flights will not be conducted over or near any non participating people or objects. • I will give right

- of

- way to any manned aircraft.• I will stay clear of FAA controlled airspace at airports (generally a five nautical mile radius) as well

as restricted and prohibited zones. • I will fly no higher than 400' and no further than 1000' from the Home Point, recognizing that the primary responsibility is to safely keep the aircraft safely within VLOS. • I will stay clear of clouds and fog (500' vertically and 2,000' horizontally). • I will perform a post

- flight check of the Phantom to determine i ts physical and electronic condition.
The aircraft itself will be marked with an N number and the aircraft airworthiness registration has already been sent in. Exemptions Requested: I respectfully request exemption from the following regulations with w hich I cannot fully comply 14CFR Part 21 Airworthiness Certification Subpart H "prescribes the procedural requirements for issuing and changing design approval, production approval, airworthiness certificates and airworthiness approval." (Summation from Exemption No. 11138, page 11) Response: "The Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, and any associated noise certification and testing requirements of part 36, is not necessary." (Summation from Exemption No. 11138, page 11 §91.103 (b)(2) (b)(2) This section deals the pilot's preparations for flight, in particular runway lengths, takeoff and landing distance information. Response: Since a quad

- copter, like a helicopter, takes off and lands vertically, a Phantom pilot would not need to know this information since there are no runways involved and the return from flight is the takeoff point. The FAA has determined that "reli ef is not necessary." (Summation from Exemption No. 11138, page 20) § 91.105 Summary: This section deals with flight crewmembers at stations.. Response: Since there are no passengers, pilots or crewmembers, I respectfully request relief from this regulatio n. § 91.119 (a) (b) (c Summary: This section deals with minimum safe altitude stating that if the power fails anywhere, an aircraft should have an altitude sufficient so that an emergency landing can occur without hazard to persons or property (91.119 a). It also sets minimum altitudes over congested areas and uncongested areas as well as has a paragraph on helicopters (91.119 b). It also sets minimum distance (500 feet) from any person, vessel, vehicle, or structure (91.119 c). Response: None of the altitu de requirements in this regulation should apply to a UAS since these aircraft are required to fly below those altitudes. Their weight, speed and GPS

- controlled Return to Home feature mitigates against a catastrophic accident. A manned aircraft is much heavier and larger than a Phantom. If a Phantom were to crash, it carries no humans, no explosive fuel and since it fliesprimarily over a single piece of private property, any damage would likely be minimal and confined to

that area. As to keeping 500' from a ny person, vessel, vehicle or structure, the purpose of real estate quad

- copter photography is to fly close to the subject structures with the permission of the owner/representative. I maintain that my nearly 90 hours flying Phantoms have provided me with sufficient skills to manage safely any approach under 500 feet. In addition, access to the property is strictly controlled. I respectfully request an exemption from this rule. § 91.121 Summary: This section details altimeter settings required to maintain t he "cruising altitude or flight level of that aircraft." It requires that the "elevation of the departure airport" be set in the altimeter or the "current reported altimeter setting of a station along the route and within 100 miles of the aircraft". Respon se: A UAV cannot comply fully with this section's altitude requirements. The Phantom is equipped with a barometric altimeter which automatically calculates the takeoff altitude {0 AGL) when the aircraft is warmed up

- the launch point becomes the "elevation of the departure" point. The altitude of the UAV is visible in the control monitor by the PIC before launch and is consistently updated as the flight progresses. I respectfully request an exemption from this rule. §91.151 Summary: This section deals with fuel requirements for VFR flights stating, among other things, that "no person may begin a flight in an airplane under VFR condition unless ... there is enough fuel to fly to the first point of the intended landing and, " .. .fly after that for at least 40 minutes (day) and 45 minutes (night)". Response: This regulation deals with 'reserve' fuel. This could include any condition that increases flight time or fuel consumption. Weather would be one factor including wind, turbulence and the necessity to divert around threatening thunderstorms. Compliance with this regulation is not possible because the 'fuel" onboard the Phantom is not aviation gas but a DC battery with a maximum flight duration of 25 minutes. Fuel management of an UV requires constant monitori ng of the battery's state

of

- charge and bringing it home before it reaches the manufacturers recommended 30% level. In our training flights, we've found that a flight of 10

- 15 minutes to be safe, returning the 6 Phantom to its Home Point around the 40% level. I respectfully request an exemption from this rule. § 91.405 Summary: This section deals with aircraft maintenance including regular inspection, the keeping of appropriate maintenance records and replacement of inoperable instruments. Response: Mainten ance on the Phantom will be done by the PIC. If, in landing, a rotor blade or two are damaged, they are quickly replaced. The traditional instrument cluster in an aircraft is replaced by a data stream from the Phantom, visible in the control monitor. Motor checks are done before each flight while rotating the blades to feel for obtrusions, and sediment in the motors. Replacement of minor parts are performed by the PIC and a major 'overhaul' that can't be easily resolved will go back to the available authorized repair facility for repair. Currently, there are no required inspections by 'authorized' maintenance personnel and there would be no space/room on board to install a placard of inoperability. I respectfully request an exemption from this rule. § 91.40 7 Summary/Response: This section addresses requirements after maintenance has been performed. Approval of the maintenance before flight is up to the PIC. Paragraph (b) refers to the prohibition of a pilot carrying passengers or crewmembers, if the flight characteristics have been substantially affected, before a rated pilot performs an operational check of the maintenance. This is a PIC'sresponsibility to preflight the Phantom and determine its airworthiness . I respectfully request an

exemption from this rule. § 91.409 Summary: This section deals with the necessity of annual and 100

- hour inspections or "progressive inspections" and approval by authorized persons which will lead to the "issuance of an airworthiness certificate." Response: There is no FAA ap proved inspection protocols nor authorized inspection personnel. The PIC handles those issues each time the Phantom is prepared for flight. The pre

- flight check list will be followed to determine its mechanical and electronic integrity. I respectfully requ est an exemption from this rule. § 91.417 Maintenance Records: This section requires a maintenance record be kept on repair, replacement and condition of vital parts (rotors, engines & airframe). Certain records must be retained for one year while other records must be kept with the aircraft even when sold to another party. Response: The details of this section would be impractical with a Phantom, but repair issues can be entered into the aircraft log. I respectfully request an exemption from this rule. Safety: The Phantom is a UAS with multiple safety features to assure a safe and efficient flight, minimizing personal injury and property damage and integrating with minimal risk into the NAS. They include: • A GPS flight system that allows for stable remote control of the aircraft. • Upon releasing controls into a neutral position the UAS maintains its current position. • A Return to Home function if electronic contact between the Remote Control and the aircraft is lost. • The ability to limit the flight ce iling of the aircraft. • Use of the 'radar' mode which instantly allows the PIC to pinpoint the UA. • The No Fly Zone control software will prevent takeoffs within a S

- mile radius of a major airport as well as provide warning in the event that the aircraft inadvertently approaches the zone while in flight. If the aircraft enters a No Fly Zone the Return to Home function kicks in and returns the aircraft to the point of takeoff. • Readout of the battery's state of charge so that there is sufficient power t o bring the UA home. • The weight, size, speed and limited flight which focuses on inanimate objects (homes) reduces the likelihood of significant personal or property damage. Flight of the UAS risks no on board lives, as in helicopter or plane photography . The safety features associated with the Phantom as well as my pre

flight checklist and procedures will assure that public safety is not adversely affected

. Public Benefits: UAS have an advantage over conventional aircraft, as they don’t carry potentially dangerous fuel, create nearly as much noise (which can disturb wildlife and residents), by taking off and landing at the property the free up airspace, use less energy (for environmental impact), and are generally safer to the public. UAS, also provide a n advantage to ground photography as it can picture subjects from angles unachievable by the ground, ensuring the Real Estate agent and buyer they know what they are getting. They also are able to get close enough to provide roof, gutter, and other inspec tions, which would normally require bringing in an additional outside person. Furthermore, Green Bee is also working with the Portland Historical Society to bring more attention to some of the homes that needhelp in the Portland Metro Area. Green Bee al so plans on trying to work with the Historical Society in

Denver as well. I respectfully request exemptions from the above listed regulations in order to conduct aerial photography of residential and commercial properties in order to assist realtors and developers in their marketing efforts.
Thank you,

Jared A Nelson 720

- 289

- 8494 greenbee@greenbeeuav.com

Phantom Specifications Listed Below:

### General Features Ready to Fly, Multifunctional Quad

- rotor System Customized H3

-2D and H3

- 3D Gimbal Support Precision Flight and Stable Hovering 25m in Flight Time & Smart Battery Auto Return

-to

- Home & Landing Advanced Power Management Intelligent Orientation Control (IOC) Easy Battery Replacement Self

-tightening P ropeller Video Downlink Support CAN

- Bus Expansion Module



### Aircraft **Weight (Battery & Propellers Included)** 1000g 

### Hover Accuracy (Ready To Fly) Vertical: 0.8m; Horizontal: 2.5m 

### Max Yaw Angular Velocity 200°/s 

### Max Tilt Angle 35° 

### Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s 

### Max Flight Speed 15m /s(Not Recommended) 

### Diagonal Length 350mm 

### Flight Time 25m ins 

### Take
**- Off Weight**  ≤1300g 

### Operating Temperature

- 10°C ~ 50°C 

### Supported Battery DJI Smart Battery


### DJI Smart Battery **Type** 3S LiPo

### Capacity 5200m Ah, 11.1V 

### Charging Environment Range 0 °C to 40 °C 

### Discharging Environment Range

-20 °C to 50 °C



### 2.4GHz Remote Control **Operating Frequency** 2.4GHz ISM 

### Communication Distance (Open Area) 1000m 

### Receiver Sensitivity (1%PER)

- 97dBm 

### Working Current/Voltage 120 mA@3.7V 

### Built
**- In LiPo Battery Working Current/Capacity**  3.7V, 2000mAh