Steve	D.		Tacang

107	Coppock	Ct. Vallejo,	California	94591 P:		(707)	704
- 0380 E:		stacangjr7@gmail.com August	2 ,	2015
**U.S.	Department	of	Transportation	Docket	Management	System 1200	New** 

**Jersey	Avenue,	SE	Washington,	DC	20590 RE:	Request	for	Exemption**  **Per	PL	112 -**  **95	§333	from	14	CFR	61.113(a)	and	(b), 14	CFR	91.103,	14	CFR	91.109,	14	CFR	91.119,	14	CFR	91.121,	14	CFR**  **91.151(a),	14	CFR	91.405(a),	14	CFR	91.407(a)(1),	14	CFR	91.409(a)(2),	14 CFR	91.417(a)	and	(b)** 
The	following	documents	have	been	include d	in	order	to	provide	supplemental information	for	this	petition’s	request	for	exemption: 1. Iris	Plus	Operation	Manual. 2. Iris	Plus	Flight	Checklist. Dear	Sir	or	Madam, This	letter	will	serve	as	a	request	for	an	exemption	of	the	above	sections	of	title	14 C FR	for	myself,	Steve	D.	Tacang,	hereafter	referred	to	as	the	petitioner,	for	the purpose	of	conducting	commercial	“ aerial	photography, videography and	survey services ”	operating	a	small	Unmanned	Aircraft	System	(sUAS)	in	FAA	controlled airspace.	As	describ ed	herein,	Steve	D.	Tacang,	is	an	experienced	user	of	multicopter sUAS	for	hobby	operations,	flying	multicopters	of	varying	sizes	under	55	pounds using	both	onboard	camera	controls	and	Visual	Line	Of	Sight	(VLOS).	The	following petition	provides	all	necess ary	information	to	justify	an	exemption	from	the	above listed	Federal	Aviation	Regulations	(FARs).

**The Small**  **Unmanned	Aircraft	System (**  **s UAS** **)** The	petitioner	will	be	flying 3D	Robotics	Iris+ that	is	equipped	with	4	propellers, onboard	camera,	and	onboard	f light	control	systems	that utilize both	GPS	and a ground control	station to	stabilize and	navigate the	aircraft.	The 3D	Robotics	Iris+ is operated	via	remote	control	in	the	2.4ghz	spectrum.The	sUAS	has a built	in	functionality	that	can	limit	the	height it	flies	above	the

ground,	distance between	the	aircraft	and	PIC,	and	restricts the	sUAS	from	flying	in class	B,	C,	and	D	airspace.	The	aircraft	also	comes	preinstalled	with	the	ability	to automatically	return	to	the	PIC	and	land	if	any	of	the	previous	res trictions	are violated,	or	if	the	connection	to	the	wireless	controller	is	lost. The	sUAS	weighs less	than	5 pounds	while	carrying	all	necessary	batteries	and cameras.	It	also	has	a	max	speed	of fewer	than 43	knots	that	can	be	limited	prior	to takeoff. The	aircraft	is	powered	via	a	lithium	polymer	battery,	which	supplies	electricity	to the	4	brushless	onboard	motors. (For	more	specifications,	please	refer	to	the	attached	owner’s	manual	[IRIS

– PLUS
Operation
- Manual
- vC
- web.pdf].	Pre
- flight	and	post
- flight inspections	will	be consistent	with	the	attached	Flight	Checklist	[IRIS
- Plus
- Flight
- Checklist
- vA.pdf]).

**Additional Specifications**  Autopilot:		Pixhawk	v2.4.5 Firmware: ArduCopter	3.2 GPS: 3DR	uBlox	GPS	with	Compass	(LEA
- 6H	module,	5	Hz	update) Telem etry	radio:		3DR	Radio	Telemetry	v2	(915	mHz) Motors: 920	kV Frame	type:		V Propellers: 9.5	x	4.5	T
- Motor	multirotor	self
- tightening	counterclockwise	(2) 9.5	x	4.5	T
- Motor	multirotor	self
- tightening	clockwise	(2) Battery: 3S	5.1	Ah	8C	lith ium	polymer Low	battery	voltage: 10.5	V Maximum	voltage: 12.6	V Battery	cell	limit:		3S **IRIS	is	compatible	with	3S	lithium	polymer	batteries	only .**  **U sing**  **a	4S	battery can	cause	permanent	damage	to	the	gimbal	electronics	and	will	void	the**  **warranty**
.Payload	capacity: 400	g	(.8	lbs)

Radio	range: up	to	1	km	(.6	miles) Flight	time: 16
- 22	minutes,	depending	on	payload Resources Hardware:		3dr.com/iris/info Firmware:		copter.ardupilot.com Software: planner.ardupilot.com	and	planner2.ardupilot.com 3DR	Store:		store.3dr.com Community: diydrones.com
**The	Unmanned	Aircraft	PIC** Steve	D.		Tacang,	the	PIC	of	the 3D	Robotics Iris +, is	an	experienced	sUAS	pilot, especially	piloting	multi
- rotor	aircra fts .	The	petitioner	has	been a	hobbyist	sUAS pilot	for	over	4 years,	and	has	piloted	this	particular	aircraft	on	numerous	occasions without	incident.	To	improve	safety	and	comply	with	the	FAA’s	requests,	a	trained observer	will	be	present	at	all	times	duri ng all	commercial flights .	The	petitioner	is also	experienced	with	maintaining	a	controlled	area	of	operations,	ensuring	the safety	of	all	nearby	persons	and	property.
**sUAS	Operation	Overview** The	sUAS	will	be	operated	to	provide aerial	photography, videography and	surv ey services ,	particularly	for	the	purposes	of	real	estate listing	enhancement,	weddings, events,	and	property	surveys. Prior	to	the	operation,	flight	restrictions	will	be	programmed	into	to	sUAS	to prevent	it	from	flying	400	feet	above ground	level	or	1500 feet away	from	the	PIC. Before	takeoff,	the PIC and Observer will	review	the	pre
- flight	checklist	(found	in IRIS
- Plus
- Flight
- Checklist
- vA.pdf )	and	survey	the	are a	to	determine	if	weather conditions	are	suitable	for	flight	and	what	the emergency	landing	sites	would	be.	All nearby	persons	in	the	operations	area	will	be	made	aware	of	the	flight	in	progress. Flights	will	not	take	place	over	densely	populated	areas	or	private	property	without the	owner‘s	permission.	Once	the	operation	is	co mplete,	the	sUAS	will	be	inspected to	determine	if	any	maintenance	will	be	needed	before	the	next	operation. Compared	to	traditional	flights	using	manned	aircraft,	flights	using	sUAS	are	much less	dangerous	and	therefor	would	not	adversely	affect	safety:

The	nature	of	these	flights	will	restrict	the	use	of	the	sUAS	to	asmall	area	where	all	nearby	persons	can	be	aware	of	the	ongoing	flight. The	sUAS	carries	no	explosive	materials	or	combustible	liquid	fuel.
The lightweight of	the	sUAS	woul d	cause	minimal	damage	in	th e event	of	an	airborne	failure, especially	when	compared	to	traditional manned	aircraft	with	airworthiness	certificates.

The	small	size	of	the	sUAS	would	allow	for	all	operations	to be conducted	within	a	clearly defined	area,	including	takeoffs	and	landings. All	flights	by	the	PIC	will begin	and	remain	outside	of	a	5 mile (8km) radius of	any	airport.	The	sUAS	has	a	mandatory,	built
- in	functionality	to	restrict	the aircraft	from	flying	within	this	radius	and	will	a utomatically	land	if	it inadvertently	violates	this	restriction.	Any	and	all	precautions	will	be	taken by	the	PIC	and	the	accompanying	Observer	to	prevent	midair	collisions	with objects	and	oth er	aircrafts ,	even	outside	the	5 m ile (8km) radius	of	airports. All	planned	operations	utilizing	the	sUAS	will	be	completed	safely.	With	the combination	of	the	preflight	safety	risk	assessments	previously	discussed	and	the inherently	reduced	risk	of	flying	a n sUAS	compared	to	a	traditional	manned	aircraft, the	PIC	wi ll	be	able	to	provide	a	level	of	safety	greater	than	the	traditional	method	of performing	aerial	based	photography,	videography,	and	survey	operations.

**Benefit	to	Public	Interest** Given	the	above	stated	evidence ,	attached	procedures and	precautions; operating the	petitioners s UAS	commercially	for	the	purpos es	of	photography,	videography and	surveying will	ultimately	be	in	the	public	interest. The	services	provided	by	the petitioner,	when	executed	with caution ,	will	exceed	the	current	level	of	safety	a s	the regulations	from	which	I	seek	exemptio n.	Granting	this	exemption	would	reduce	the need	for	traditional	forms	of	aerial	photography,	videography	and	surveys,	which relies	primarily	on	the	use	of	larger	aircrafts	running	on	combustible	fuel.	Posing pot ential	risk	to	the	public,	these	traditional	methods	are	much	more	dangerous than	operations	performed	by a sUAS. Granting	this	exception	will	also	allow	greater	access	to	commercial	aerial	services that	were	not	previously	economically	sufficient	for	man y	businesses	and individuals. The	cost	of	sUAS	operations	is	significantly	lower	than	traditional	aerial photography,	making	these	services	available	to	smaller	businesses	and/or individuals	that	otherwise	may	not	be	able	to	afford	them.	This	in	turn	allow s businesses	to	better	serve	their	clients,	increasing	the	public	benefit	as	a	whole.**Conclusion**

All	commercial	sUAS	flights	by	the	petitioner	shall	satisfy	the	criteria	provided	in Section	333	of	the	Reform	Act	of	2012,	including:	size,	weight,	speed,	flight	within VLOS,	distance	from	PIC,	distance	from	airports,	operation	capabilities,	maintaining safety,	and	the	benefit	to	the	public. These	qualifications	more	than	justify	granting the	petitioner, Steve	D.	Tacang,	with	an	exemption	to	the	stated	se ctions	of	title	14 CFR. In	addition, g ranting	my,	Steve	D.	Tacang,	request	for	exemption	will	reduce	current risk	levels	and	thus	enhance	safety.	My	sUAS	craft	do	not	contain	potentially explosive	fuel,	is	smaller,	lightweight	and	more	maneuverable	than	c onventional video	and	photographic	aircrafts	with	much	less	flight	time.		I	will	operate	at	lower altitudes	and	in	controlled	airspace	eliminating	potential	public	risk	flying	to	and from	established	airfields. The	requests	of	this	petition	are	similar	to those	of Marcus	D.	Melhus,	Ralph	J. Apel, Gerald	R	Tookes , Kenneth	Dungey and Joseph	Busalacchi all	of who m have received	Section	333	exemptions	for	use	of	comparable	aircraft	for	similar operations. Thank	you	for	your	time	and	consideration. Respectfully	Submitted , Steve	D.	Tacang Petitioner