Douglas J. Linesch 7089 Running Fox Court Florence, KY 41042 dlinesch@fuse.net 859-466-8183

February 08, 2016

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I, Douglas J. Linesch, would like to formally submit an exemption from part 21, subpart H; and Sections, 45.23(b), 91.119, 91.121, 91.151(a)(1), 91.40S(a), 91.407(a)(1), 91.409(a)(1)and(2), 91.417(a)(b), oftitle 14 Code of Federal Regulations (14 CFR). This proposal exemption would allow operation of unmanned aircraft systems (UAS) forthe purpose ofaerial videography, aerial photography and aerial survey for real estate, construction firms, landscape gardens, special events to include but not limited to weddings, private or public parties/events, business advertising, promotional events and sporting events. Regarding the Unmanned Aircraft PIC:
Iwill operate the UAS, more specificallythe DJI Phantom Ill, which is an unmanned aircraft (UA or PHANTOM), comprised ofan attached high definition camera and atransportable ground station. I hold an ATP Certificate with fourtype ratings and I'm approaching eleven thousand hours offlighttime. I currently am a captain on a Falcon 900. I also hold a Flight Instruction Certificate for airplane single and multiengine land, and instrument. Having flown thousands ofhours in a multitude ofaircraft, I am well aware ofthe importance ofpre- flight planning and the significance of being safety oriented. Safety is extremely important and is my number one priority. Flying a UAS is no exception when it comes to fitness offlight and I intend to operate the UAS as Iwould any aircraft, always being in peak physical and mental condition. This will allowforsafe operations on the ground and in the air,just as it is done in manned aircraft. Regarding the Operation ofthe Unmanned Aircraft:
With my clear understanding of FAA regulations, my experience in flying in all kinds ofairspace and my safetyfirst attitude, I believe that I should be granted an exemption. I am well aware ofthe importance ofsafe flight operations and planning flight paths that minimize any overflight ofcrowds or in the vicinity ofother manned aircraft. I am new to operating a UAS and I know how important proper training is. Because ofthis, Ijust enrolled for a 2 day drone training class taught by a CFI at Lunken Airport in Cincinnati. This includes both ground instruction and going to a local park forflight instruction. Preflight and post-flight checklists and UAS examinations will help detectany abnormalities priorto flight and afterflight. Any UAS unable to satisfy safety checklists will be removed from service until the issue can be resolved. The UAS will not be operated above 200 feet AGL and will not be flown in wind conditions greaterthan 10 knots. The UAS will operate in temperatures between 0 degrees Celsius and 40 degrees Celsius (32 degrees Fahrenheit -104degrees Fahrenheit) as that is the range forthe craft. Flights outside those temperature parameters will not be attempted. Furthermore, the UAS will

### maintain at least the Basic VFR Weather Minimums prescribed in 14CFR 91.155 and operations will only commence during day visual meteorological conditions.

Ifa property being enhanced by videography or photography is within 5 nautical miles ofatowered airport, Iwill call the control tower and request permission to operate the UAS. Upon contact with the tower manager Iwill alertthem to the location ofthe propertythat is to be filmed and provide the proximity ofthat propertyto the airport. Iwill also give at least a minimum ofa 24 hour notice before filming or photographing the property. Ifpermission is not granted, operations with not be conducted.
Before operating within close proximityto another structure, building or person, the ownerand/or those who Jive atthe aforementioned will be given notice that aerial photography and/orvideography will commence. Any complaint by a neighboror member ofthe public worried abouttheirprivacy being invaded, will be ensured that only the property being videoed will be used for marketing purposes. If this is notsufficient, the DJI Phantom Ill will immediately be brought back to the ground and the videography and/or photography will cease until the complaint is resolved. The UAS will only be operated within visual line ofsight visual contact between myselfand the unmanned aircraft.This will further ensure safe operational control as Iwill always have visual line of sight on the UAS in orderto scan the airspace it is operating in so as to see and avoid otheraircraft, airborne objects orobjects on the ground. Moreover, I will only operate in congested areas with another person (spotter) in orderto help spotthe aircraftfrom otherangles to verify operations will be conducted safely. Iwill always be in verbal contact with the spotter. Additionally, in orderto further enhance safety, flights will end when battery reserve reaches 25 percent. The UAS has a 15.2 volt battery, allowing flight operations for up to 23 minutes. I have also purchased asecond battery allowing for an additional 23 minutes offlight time. Operations with the UAS will notoccur under IFR conditions. It is my understanding that grantingthis request would not adversely affect safety since operations would be in accordance with current UAS rules. Suggested Public Federal Register Summary:
"The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS} underthe new FAA "Summary Grant" approach, announced April 9th, 2015 thatwill hasten the Section 333 exemption approvals for many commercial UAS operators priortofinalizing the small UAS proposed rules published this past February."
It is my understanding thatthe FAA will still review each Section 333 petition individually. However, I am hoping thatthe agency will accept my particular petition, include it in the next summary grant and issue an exemption to myselfon the presumption thatthe FAA has alreadygranted a previous exemption similarto this request. Currently, the new interim policy includes the granting ofa Certificate ofWaiver orAuthorization (COA) forflights at or below 200 feetto any UAS operatorwith a Section 333 exemption for aircraftthatweigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line ofsight (VLOS) ofthe pilots, and stay certain distances away from airports or heliports such as 5 nautical miles (NM) from an airport having an operational control tower or3 NM from an airport with a published instrumentflight procedure, but notan operational tower; or2 NM from an airportwithout a

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published instrumentflight procedure oran operational tower; or 2 NM from a heliportwith a published instrumentflight procedure. It is also understood thatthe "blanket" 200- foot COA allows flights anywhere in the country except restricted airspace and otherareas, such as major cities, where the FAA prohibits UAS operations.
UAS Description:

I am asking for an exemption fora UAS up to 55 pounds because Iwill be using a craftthatwill be flown operationally, weighing less than ten pounds. More specifically, Iwill be operating a DJI Phantom Ill, which will be qualified as a UAS. The UAS can flyfor up to 23 minutes in temperatures between 0 degrees Celsius and 40 degrees Celsius. The UAS has aSony EXMOR camera mounted on itwith a gimbal. The remote control allows for a smartphone ortabletto be used in orderto operate the drone with a live feed from the Sony camera mounted on it. This permits operation with a high level ofsafety.
In the event a loss ofcommunication occurs with the UAS, itwill automatically rise up vertically to a safe height before beginning an automatic return to home function. Ifthe control signal can be reconnected in flight, I will take oversafe operations again ifcommunication is reestablished. However, in the case of a GPS failure the craft will be able to be manually flown to a safe landing. The craft operates electronically, carries no flammable fuel, has an integrated GPS pilot system, location information along with height in AGL, speed, battery life, has programmed no-fly zones forcontrolled airports and provides direction oftravel distance from the pilot.
Based on the size ofthe UAS, myexperience of being a pilot, and operational goals, this request appears to be well suited forapproval using the current criteria outlined in Section 333 ofthe FAA Modernization and Reform Act of2012 (including new interim policies). I believe thatthis gives the FAA good cause to find thatthe UAS operation enabled by this exemption is in the public interest.

# ;J;at~P Douglas J. Linesch