September 10, 2015

Name and Address of Petitioner:

Bradley Wood

495 Grove Creek Dr

Pleasant Grove UT 84062

602

- 402

- 8546 bradley.j.wood@gmail.com

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations 14 CFR , Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l), 91.417(a)&(b)

I, Bradley Wood , the petitioner, request exemptions in order to legally operate an Unmanned Aircraft Systems (UAS), a DJI Phantom 3 Professi onal, in the National Airspace System. The DJI Phantom 3 Professional this petitioner seeks exemption to use will be referred to as ‘Named UAS’. All flights of the ‘Named UAS’ will be flown by line of sight (LOS) and performed under 400' above ground line (AGL). The ‘Named UAS’ does have GPS guidance and "return to home" safety feature installed. The ‘Named UAS’ also uses a smartphone to enhance controls by showing current AGL and visual location of the ‘Named UAS’ to the subject and its surroundings. The p etitioner wishes to be granted the exemption for use of the ‘Named UAS’ for commercial videography and photography of:

1. Residential and Commercial Real Estate, for marketing the sale of each.

2. Construction Process (Residential and Commercial), providing a visual review of the construction process to be used for marketing of a construction company or documentation to be provided to the owner.

3. Property Survey, providing a visual review of the property to the land owner to be sold, purchased, or prior to construction.

4. Property Inspection, providing a visual review of existing conditions to the land owner.

5. Property Landscape, provide visual documentation of ‘befo re and after’ improvement to a land

o wner.

The Petitioner believes the use of the DJI Ph antom 3 Professional is more economical and safe to use than a manned aircraft for the aforementioned purposes. In the past, a manned aircraft would be used to provide a visual review of land and property, which involves pilot fees, inspections,

and use of an airport. Use of the ‘Named UAS’ rather than a manned aircraft is more economical to the consumer, and beneficial to the general public due to its small size, low noise, and minimal potential for accident.

Additionally, I

, the petitioner, would like to point out that in order to have a successful business it is in my best interest to be safe. That safety will directly benefit the public because that safety relates to protecting my investment in a UAS. If the UAS is damaged, so is my means of providing a service and profiting from it. Also, if I don’t provide a safe service to my customers

, they will be less likely to recommend me to their neighbors. So I have to provide a safe service inorder to gain the trust of other potential customers.

My request for the following exceptions are based on those provided to Exemption No. 11623, 11650, 11664, and 11734. I reviewed and quote these public letters because of the similarities to the use of a UAS to capture photography and videography of real estate and co nstruction for hire.

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations:

14 CFR Part 21

Certification Procedures For Products and Parts

REASON FOR EXCEPTION

It has been determined that similar UAS’s do not require an airworthiness certificate as granted in Exemption No. 11623, 11650, 11664, and 11734.

14 CFR 91.7(a) Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy

condition.

REASON FOR EXCEPTION

It has been determined that similar UAS’s do not require an airworthiness certificate, however the petitioner will ensure airworthiness through the combined use of the manufacturer's Operations Manual and preflight checks.

14 CFR 91.119(c)

Minimum Safe Alti tudes:( c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or structure.

RE ASON FOR EXCEPTION The use of ‘Named UAS’ will be flown no higher than 400’ AGL in LOS over developed and developing residential areas that may be considered congested areas. That will not always be the case when providing a ‘Property Survey’ flight becau se they could be conducted over empty lots or acreages with no structures. This will minimize the amount of bystanders present or in the surrounding area. In the case of flying over or near existing private property while providing a

‘Residential and Comme rcial Marketing’, ‘Construction Process’, ‘Property Inspection’, and ‘Property Landscaping’ landowners will be notified in person by the petitioner, or by a card left behind by the petitioner, of an occurring ‘Named UAS’ flight. The petitioner also propose s to display a caution sign on site while a ‘Named UAS’ flight is ongoing. The petitioner will review with the landowners of associated risks to people and property. Due to the small size of the ‘Named UAS’ the associated risk to persons, vessels, vehicles , and structures is not comparable

to manned aircraft and should be taken into consideration.

14 CFR 91.121 Altimeter Settings:

REASON FOR EXCEPTION

The ‘Named UAS’ does not have a barometric altimeter. It does have a GPS that will calculate

altitude. The petitioner will limit flights to a maximum altitude of 400 feet AGL as granted in Exemption No. 11623, 11650, 11664, and 11734.

14 CFR 91.151(a)(l)Fuel requirements for flight in VFR conditions:( a) No person may begin a flight in an airplane

under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed( 1) During the day, to fly after that for at least 30 minutes.

REASON FOR EXCEP TION The ‘Named UAS’ provides low battery warnings to indicate when you should return the ‘Named

U AS” to the launch point. A fail

- safe automatic landing will occur if the battery reaches critical low voltage. The ‘Named UAS’ will be landed upon the 1st lo w battery alert. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point. All flights will be done during the day and at an appr opriate time as to not be a nuisance to others.

14 CFR 91.405(a) Maintenance required: Each owner or operator of an aircraft- (a) Shall have that aircraft inspected as prescribed in Subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.

REASON FOR EXCEPTION The petitioner shall inspect the aircraft prior to every flight. The petitioner plans to follow

manufacturer's recommend ed preflight checklist. Reference given to the Operations Manual.

14 CFR 91.407(a)(l) Operation after maintenance, preventive maintenance, rebuilding, or alteration: (a) No person may operate any aircraft that has undergone maintenance, preventive mainte nance, rebuilding, or alteration unless( 1 )It has been approved for returned to service by a person authorized under 43.7 of this chapter

. REASON FOR EXCEPTION The petitioner who has the responsibility for the operation and safety of the ‘Name UAS’ will follow the manufacturer's suggestions for maintenance and repair. Including the use of suggested replacement parts.

14 CFR 91.409(a)(l) & (2) Inspections: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annu al inspections and is entered as an "annual" inspection in the required maintenance records.

REASON FOR EXCEPTION The petitioner will follow manufacturer’s suggestions to ensure that the ‘Named UAS’ is in a condition for safe flight.

14 CFR 91.417(a) & (b) Maintenance Records: (a) Except for work performed in accordance with 91.411 and 91.413, each registered owner or operator shall keep the following records (l)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v)( vi) for the periods specified in pa ragraph (b) of this section: ( 1 )(2)(3)

REASON FOR EXCEPTION The petitioner will keep a record of all repairs and modifications. The petitioner also proclaims touse approved manufactured parts for repairs and modifications.

SUMMARY

I, Bradley Wood, the petitioner

, submit a request for exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations 14 CFR, Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l), 91.417(a)&(b) in order to legally operate an Unmanned Aircraft Systems (UAS), a DJI Phantom 3 Professional, in the National Airspace System in order to take aerial video and photography of real estate and construction

processes.