1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C.

____________________________________ ___ In the Matter of Petition for Exemption of ) Eric Kulmala
, ) PETITIONER ) Regulatory Docket No. FAA

- 2015

-

______ __ ) For An Exemption Seeking Relief from Certain ) Requirements of Title 14 of the Code of ) Federal Regulations Concerning Co mmercial ) Operation of Unmanned Aircraft Systems ) Pursuant to Section 333 of the FAA ) Modernization and Reform Act of 2012 ) ( Pub. Law. 112

- 95 ) and 14 CFR Part 11 ) ) Before the Secretary of the ) DEPARTMENT OF TRANSPORTATION )

_________________________________ ______ )

REQUEST FOR SUMMARY GRANT

Communications with respect to this Petition shall be sent via U.S. Mail and Email to:

Lucas A. Armeña for: Eric Kulmala
, Petitioner 49 Brownstone Court 41 Page Drive Fletcher, NC 28732 Oakland, NJ 074 36 Phone: (917) 414

- 6969 Phone: (201) 294

- 7316 Email: lucasarmena@gmail.com Email: ericpentti@mac.com

DATE SUBMITTED: July 8, 2015

Summary for publication to the Federal Register stating

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1. SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, PART 61, PART 91 SUBPART E, AND SECTIONS 61.113 (a) & (b), 45.23, 45.27, 45.29, 91.7 (a), 91.9, 91.103, 91.105, 91.109, 91.119, 91.121, 91.151, 91.203 (a) & (b), and 91.401 through 91.417 CONCERNING COMMERCIAL OPERATION OF UNM ANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

2. Petitioner seeks exemption in order to use his UAS for commercial use.2 DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION Regulatory Docket No. FAA

- 2015

-

______ __
Eric Kulmala , Petitioner 1

Specific Regulations from which the exemption is requested: 14 CFR Part 21 14 CFR Part 61 14 CFR §§ 61.113 (a) and (b) 14 CFR § 45.23 14 CFR § 45.27 14 CFR § 45.29 14 CFR § 91.7 (a) 14 CF R § 91.9 14 CFR § 91.103 14 CFR § 91.105 14 CFR § 91.109 14 CFR § 91.119 14 CFR § 91.121 14 CFR § 91.151 14 CFR §§ 91.203 (a) and (b) 14 CFR Part 91, Subpart E (§§ 91.401

– 91.417)
Petitioner’s applicable situation and material respects to relief are similar: Petitioner requests use of Unmanned Aircraft Systems for aerial data collection, 2 and the situation and circumstances presented are similar in material respects to previous Grants of Exemption issued by FAA. This petition for exemption is in the public interest for which a statement of benefit is iterated below.

The Unmanned Aircraft Systems proposed by the petitioner are: 3 DJI, Phantom 3, Rotorcraft

- 4 rotors, 2.82129 lbs. 3D Robotics, Solo, Rotorcraft

- 4 rotors, 3.30693 lbs. 3D Robotics, X8

- M, Rotorcraft

- 8 rotors, 7.71618 lbs. 3D Robotics, Aero

- M, Fixed

- wing

- 1 rotor, 6.61387 l bs.

1 For consistency and ease of FAA review, Petitioner’s request generally tracks, in format and content, the requests for exemption filed by previous petitioners for commercial use. Petitioner gratefully acknowledges all of their work in this regard.

2 Aeri al data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particula te measurement, etc.), or any other gathering of data by instruments aboard the UA.

3 Requisite information for FAA to process this petition is provided as make, model, type, and weight. Petitioner highlights that the Unmanned Aircraft Systems (UAS) list ed will not carry passengers or crew or any hazardous or explosive cargo, not exceed an operational weight of 55 pounds including payload, and not operate at speeds exceeding 87 knots.Submitted on 8, 2015

for: Lucas A. Armefia
49 Brownstone Court Fletcher, NC 28732 Phone: (917) 414-6969 Email: lucasarmena@gmail.com Krossblade, SkyProwler VTOL Transformer UAV, VTOL fixed-wing - 6 rotors, 2.20426 lbs. CyPhy Works, LVL 1, Rotorcraft - 6 rotors, 2.00000 lbs. senseFly, eBee, Fixed-wing - 1 rotor, 1.52119 lbs. senseFly, eBee RTK, Fixed-wing - 1 rotor, 1.60938 lbs.

Extent of relief and reasoning: In order to allow Petitioner use of his Unmanned Aircraft Systems for commercial purposes. Petitioner seeks this exemption in order to legally conduct business and comply with all Federal regulations and standards put forth by the Federal Aviation Administration (FAA) while operating his Unmanned Aircraft Systems (UAS).

Reasons this exemption would not adversely affect safety or how the exemption would provide a level of safety at least equal to the existing rule: By adhering to guidelines set forth by the FAA, Petitioner would not be going above the recommended altitude, nor flying at night, therefore avoiding hazardous conditions such as interference with manned aircraft. Petitioner plans to provide notification to FAA at least three (3) days prior to any commercial use, or otherwise prescribed or superseded by grant, waiver or authorization. Additionally, Petitioner plans to regularly perform test or training flights, as well as maintaining monthly maintenance logs to ensure the UAS are in proper working order for each job or event, as to prevent property damage or bodily injury.

Statement regarding exemption grant beneficial to the public interest: Granting the exemption for Petitioner would provide the ability for him to efficiently, legally, economically and safely perform aerial video, photography, and other sensor data processing for lifesaving or humanitarian events, special events, emergencies and disasters, academia and education, sporting events, land surveying and mapping, real estate, commercial inspections and maintenance, as well as providing for other contemplated and uncontemptated uses for the public's Safety and Happiness over certain areas of the United States. Using UAS technology would greatly reduce negative impacts on the environment, provide a safer alternative for businesses to conduct land and equipment inspections, and greatly reduce decision-making cycles for clients and the at-large public.

Proposed operations: Contemplated operations are listed in the above statement of public benefit, but not limited, as uncontemplated operations may arise and be developed. Regardless, at all times Petitioner shall abide by Federal regulations and standards of the FAA.

/Signed/ Eric Kulmala, Petitioner 41 Page Drive Oakland, NJ 07436 Phone: (201) 294-7316 Email: ericpentti@mac.com

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