**Page 1**  

### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**

**ROBERT H. CARLISLE**

FOR AN EXEMPTION SEEKING RELIEF FRO M THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION O F BLADE CHROMA, YUNEEC TYPHOON Q500 , DJI PHANTOM 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112
- 95)

Submitted on November 2 4 , 2015
ROBERT H. CARLISLE 134 MORNINGSIDE RD. NILES , OH 44446 (3 30 ) 883
- 4566**Page 2**  **TABLE OF CONTENT S** 
Page GLOSSARY OF A BBREVIATIONS.....................
. .................................................. .... .......... ... ...3 T HE SPECIFI C SECTIONS OF 14 C .F.R
.. ................... ......................... . ..... ... .. ....... . .. .. .... . .... . . .. . ... 4 SUMMARY.....................................................................................................................
.... ....... ... ..5 IN TRODUCTION AND INTERESTS OF PETITIONER..............................................
.... .... ... ....5 BACKGROUND............................................................................................................
.... ... ... ......6 BASI S FOR PETITION...................................................................................................
... . ... ........7 NAME AND ADDRESS OF PETITIONER..............
...... ............ .. ............. ...... ... ........ . .. ...8 THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH ROBERT H. CARLI SL E SEEKS EXEMPTI ON..............
........................ ... ..... .. ... .. ... . . ..... 9 THE EXTENT OF RELIEF ROBERT H. CARLISLE SEEKS AND THE REASON ROBERT H. CARLISLE SEEKS THE RELIEF...............
... ... ... . ....12 THE REASONS WHY GRANTING ROBERT H. CARLISLE REQUEST WOULD BE IN THE PUBLIC INTEREST ...........................................
............. .. .. . .. . .. ... 15 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY........................................................................
.. .. . . ... . ..1 7 CONCLUSION....................................................
............................................................... . . ... .. ....2 3 APPENDIX A
................ ... ................................................................................................... . .. . . .. ...2 4 BLADE CHROMA TECHNI CALDATA SHEET APPENDIX B
................ ... ................................................................................................... ....... ...2 7 YUNEEC TYPHOON Q500 TECHNI CALDATA SHEET APPENDIX C
................ ... ........................................ ........................................................... ....... ... 31 DJIPHANTOM 3 TECHNI CALDATA SHEET APPENDIX D
................ ... ................................................................................................... ....... ... 3 7 MAI NTENANCE LOG**Page 3**  **GLOSSARY OF ABBREVIATIONS**
AGL Above Ground Level AOI Area of Interest AMA Academ y of Model Aeronautics ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization ESC Electronic speed control FPV First Person View FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LI
- PO Lithium Poly mer battery LOL Loss of Link MPH Miles Per Hour NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot In Command RCV Radio Controlled vehicle Section 333 FAA Modernization and Reform Act of 2012 (FMRA) SO Safety Observer SO P Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing**Page 4**  **The specific sections of 14 C.F.R**  **.** 14 C.F.R. Part 21; Certification Procedures for Products a nd Parts 14 C.F.R. 45.23(b); D isplay of marks; general **14 C.F.R. 61.113(a) & (b);**  Private pi lot privileges and limitations: Pilot in command. **14 C.F.R 91.7(a) ;**  Civil aircraft airworthiness **14 C.F.R. 91.121;** Altimeter settings **14 C.F.R. 91.151( b**  **);** Fuel requirements for flight in VFR conditions **14 C.F.R. 91.405(a);** Maintenance required. **14 C.F.R. 91.407(a)(1);** Operation after maintenance, preventive maintenance, rebuilding, or alteration. **14 C.F.R. 91.409(a) (1)**  **& (a) (2};**  Inspections **14 C.F.R. 91.417(a) & (b);** Maintenance records**Page 5**  **SUMMARY**
ROBERT H. CARLI SL E seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b) , 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit ROBERT H. CARLISLE to operate an Unmann ed Aircraft System (UAS) for the commercial purpose of conducting search & rescue, aerial inspections, aerial video and photography , fl y- over video over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** My name is ROBERT H. CARLISLE , and I am a drone operator (pilot) with expertise and knowledge in all aspects of o perating multiple types of UAS's along with camera set up and operation. ROBERT H. CARLISLE also provides clients with the highest quality digital content for us e in their search & rescue operations, aerial inspections, and aerial video photography
. ROBERT H. CARLISLE is a member of AMA and has 25 ye ars of radio controlled aircraft operation and 2 years of drone experience
. The objective of ROBERT H. CARLISLE ae rial video and photography operations is to provide search & rescue, aerial inspections, high quality imag ing for a variety of commercial and residential uses. ROBERT H. CARLISLE will also provide knowledge of UAS ’s and promote safe UAS operations.**Page 6**  **BACKGR OUND**  Unmanned Aircraft Sy stems: BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS
. ROBERT H. CARLI SL E seeks an exemption to operate Blade and Yuneec sy stems for compensation or hire within the NAS. The BLADE CHROMA, YUNEEC TYPHOON Q500, and DJI PHANT OM 3 are v ertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS). The BLADE CHROMA has a maximum gross weight of 45.9 ounces while having a length of 15.7 inches , height of 9.5 inches and a maximum speed of approximat ely 30 mph
. YUNEEC TYPHOON Q500, DJI PHANTOM 3 has a maximum gross weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The BLADE CHROMA, YUNEE C TYPHOON Q500, DJI PHANTOM 3 UA S ’ s are equipped with four main rotors; driven by L ithium Poly

mer b attery

powered electric motors. The BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UA S ’s that will be operated b y ROBERT H. CARLISLE will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Id entification and Registration Markings.**Page 7**  **BASIS FOR PETITION** Petitioner, ROBERT H. CARLISLE , p ursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Sy stems, hereby petitions the Administrator to commercially operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, ROBERT H. CARLISLE ’ s operation of BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, ROBERT H. CARLISLE requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91. 417(a) & (b), as these sections set forth requirements for maintenance that onl y apply to aircraft with an airworthiness certificate. ROBERT H. CARLI SL E submits that the requested relief is proper since an equivalent level of safety will be ensured. ROBE RT H. CARLISLE will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS ’ s using the methods, techniques, and practices prescribed in the operating documents (i.e., and BLADE CHROMA, YUNEEC TYPH OON Q500, DJI PHANTOM 3 Instruction Manual s ). Furthermore, ROBERT H. CARLISLE will document and maintain all maintenance records for the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s. Relief from certain requirements of Section 61.113(a) and (b) , entitled Private pilot privileges and limitations: Pilot in command, is requested b y ROBERT H. CARLISLE to the extent necessary to allow a Pilot in Command (PI C) who has demonstrated, by meeting minimum flight
- hour requirements, that the PIC is able to s afel y operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. ROBERT H. CARLI SL E seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, ROBE RT H. CARLI SL E submits that he will ensure that the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s are in an airworthy condition, prior to every

flight, by determining that the UAS ’ s are in compliance with the operating documents (i.e, and BLADE CH ROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 Instruction Manuals, and that the aircraft are in a condition for safe flight.**Page 8** 

ROBERT H. CARLI SL E also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UA will not have a typical barometric altimeter onboard. However, altitude information of the BLA DE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UA will be provided to the PI C via Global Positioning Sy stem (GPS) equipment an d radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with ROBERT H. CARLI SL E ’ s operation of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA within visual line of sight, at or below 500 feet AGL , will ensure a level of safety equivalent to Section 91.121. Additionally , ROBERT H. CARLISLE seeks an exemption from the requirements of Se ction 91.151(b), entitled Fuel Requirements for flight in VF R conditions. ROBERT H. CARLISLE submits that safety

will not be affected by

operation of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough b attery power to fl y for a total duration of approximately 2 5 minutes
. Battery power indicators are also able to show how much battery power is left, as well as how much time is needed to return safel y back to the point of take off. In accordance with 14 C .F.R. § 11.81, ROBERT H. CARLISLE provides the following information in support of its petition for exemption: **A. Name and Address of the Petitioner.** The name and address of the Petitioner and point of contact is: ROBERT H. CARLI SL E 134 M orningside Rd. , Niles , OH 44446 (3 30 ) 883
- 4566 Email: r.carlisle50 @gmail.com**Page 9** 

**B. The Specific Sections of 14 C.F.R. From Which ROBERT H. CARLISLE**  **Seeks Exemption.**  **1 .**  **ROBERT H. CARLISLE Seeks Exemption from the Requirements of Section**  **61.113(a) a**  **nd (b):** (a) Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (i ) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. (ii) A private pilot may , for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— a. The flight is only

incidental to that business or employ ment; and b. The aircraft does not carry passengers or property

for compensation or hire. **2. ROBERT H. CARLISLE**  **Seeks Exemption from The Requirements Of Sect ion**  **91.7(a) :**  (a) Section 91.7, entitled c ivil aircraft airworthiness, subsection (a), states the following: a. No person may

operate a civil aircraft unless it is in an airworthy condition. **3. ROBERT H. CARLISLE**  **Seeks Exemption from The R** **equirements Of Section 91.121:**  (a) Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (i) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the c ase may be, b y reference to an altimeter that is set, when operating UA b elow 18,000 feet MSL, to: a. The current reported altimeter setting of a station along the route and within 1 00 nautical miles of the aircraft; b. If there is no station within the area of this section, the current reported altimeter setting of an appropriate available station; or c. In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.**Page 10** 

**4. ROBERT H. CARLISLE**  **Seeks Exemption from The Requirements Of Section**  **91.151(b):** Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may

begin a flight in a rotorcraft under VFR conditions unless considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assumin g normal cruising speed, to fly after that for at lea st 20 minutes. **5 .**  **ROBERT H. CARLISLE Seeks Exemption from The Requirement Of Section**  **91.405(a):** (a) Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— ( i ) Shall have that aircraft inspected as required and shall between required inspections have discrepancies repaired as required. **6. ROBERT H. CARLISLE**  **Seeks Exemption from The Requirements Of Section**  **91.407(a)(1) :**  (a) Section 91.407, entitled Operation after m aintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (i) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless
-- (a) It has been approved for return to service b y a person authorized under § 43.7 of this chapter [.] **7. ROBERT H. CARLISLE**  **Seeks Exemption from The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2):**  ( a) Section 91.409, entitled Inspections, subse ction (a), states the following: (i) 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
-- a. An annual inspection in accordance with part 43 o f this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or b. An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.**Page 11** 

**8. ROBE**  **RT H. CARLISLE Seeks Exemption from the Requirements of Sections**  **91.417(a) and 91.417(b):** (a) Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (i) Except for work performed in accordance with §§ 91.41 1 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: a. Records of the maintenance, preventive maintenance, and alteration and records of the 100
- hour , annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include
-- 1. A description (or reference to data acceptable to the Administrator) of the work performed; and 2. The date of completion of the work performed; and 3. The signature and certificate number of the person approving the aircraft for return to servic e. b. Records containing the following information: 1. The total time in service of the airframe, each engine, each propeller, and each rotor. 2. The current status of life
- limited parts of each airframe, engine, propeller, rot or, and appliance. 3. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. 4. The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft and its appliances are maintained. 5. The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. An y the AD or safety directive involves recurring action, the time and date when the next action is required. 6. Copies of the forms prescribed b y § 43.9( d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. c. The owner or operator shall retain the following records for the periods prescribed: 1. The records specified in paragraph (a) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed.**Page 12**  2. The records specified in paragraph (a) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. 3. A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. **C. The Extent Of Relief ROBERT H. CARLISLE**  **Seeks And The Reason ROBERT**  **H. CARLISLE Seeks The Relief.**  **1. Extent of Relief**  **ROBERT H. CARLISLE Seeks**  **a nd T**  **he Reason ROBERT H. CARLISLE**  **Seeks Re lief From**  **Section 61.113(a) And (b):** Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C who has met certain flight
- hour and currency requirements, to conduct the proposed UA flight operations for compensation or hire. (a) T his relief is requested since the limitations set forth in Section 61.113(a) and (b) S tate that a private pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or employ

ment if: 1 . The flight is onl y incidental to that business or employ ment; and 2 . The aircraft does not carry passengers or property

for c ompensation or hire. As set forth more full y be low, ROBERT H. CARLISLE submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the Blade Chroma, Yuneec T yphoon Q500, DJI PHANTOM 3 UAS unless that PI C has met certain flight
- hour and currency

requirements, demonstrating that the PI C is able to safely operate either the Blade Chroma, Yuneec Ty phoon , DJ I PHANTOM 3 UAS ’s in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency

maneuvers, as well a s maintaining appropriate distances from people, vessels, vehicles and structures. Further, ROBERT H. CARLISLE submits that all flights of the BLADE CHROMA, YUNEEC TYPHOON , DJI PHANTOM 3 UAS ’ s, conducted b y the PIC pursuant to the grant of this Petiti on: 1. Will be incidental to ROBERT H. CARLISLE ' s business; and 2. Will not carry

passengers or property for compensation or hire.**Page 13** 

**2. Extent Of Relief ROBERT H. CARLISLE**  **Seeks And The Reason ROBERT H.**  **CARLISLE See**  **ks Relief From Section 91.7(a):** Relief from Section 91.7(a) entitled Civil Aircraft A irworthiness, is requested to the extent required to allow ROBERT H. CARLISLE to determine that the BLADE CHROMA, YUNEEC TYPHOON , DJI PHANTOM 3 UAS ’ s are in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., Blade Chroma, Yuneec Ty

phoon , DJI PHANTOM 3 Instruction Manual s ). ROBERT H. CARLI SL E seeks the requested relief because the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA S ’ s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, ROBERT H. CARLISLE will ensure that the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 Instruction Manual s ) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. **3. Extent Of Relief ROBERT H. CARLISLE**  **Seeks And The Reason ROBERT H.**  **CARLISLE Se**  **eks Relief from Section 91.121:** Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Sin ce the FAA requires that any altitude information concerning UA operations be reported to air traffic control (ATC) in feet above ground level (AGL), ROBERT H. CARLI SL E seeks the requested relief because the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA S ’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent nece ssary to comply

with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA S’ s are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads
- up display

of the GCS.**Page 14** 

**4. Extent o f Relie**  **f ROBERT H. CARLISLE**  **Seeks A**  **nd The Reason ROBERT H.**  **CARLISLE Seeks**  **Relief From Section 91.151(b):** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery p owered BLADE CHROMA, YUNEEC TYPHOON , DJI PHANTOM 3 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15 .5 minutes to the first point of intended landing and, assuming normal cruisin g speed, to fly after that for at least 4.5 minutes. ROBERT H. CARLISLE seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UA will severel y constrain the practicality of any aerial video or still photo flight operations that ROBERT H. CARLISLE proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the BLADE CHROMA, YUNEEC TYP HOON Q500, DJ I PHANTOM 3 UAS ’ s, the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 operating documents, and ROBERT H. CARLISLE ’ s proposed operating limitations, ensure that ROBERT H. CARLISLE will safel y operate the battery powered BLADE CHROMA, YUNEEC T YPHOON Q500, DJ I PHANTOM 3 UA S’s during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 15 .5 minutes to the first point of intended landing and, assuming no rmal cruising speed, to fly after that for at least 4.5 minutes. **5. Extent o f Relief**  **ROBERT H. CARLISLE Seeks And The Reason**  **ROBERT H. CARLISLE**  **Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And**  **91.417(a) & (b):** Since Secti ons 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y apply to aircraft with an airworthiness certificate, ROBERT H. CARLI SL E requests relief from these Sections because the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s do not require airworthiness certificates. As set forth more fully below, the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, ROBERT H. CARLISLE will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS ’ s using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., ROBERT H. CARLISLE Aerial Operations Manual, Monthly Maintenance Lo g, and BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 Instruction Manual s ). Furthermore, ROBERT H. CARLISLE will document and maintain all maintenance records for the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s.**Page 15** 

**D . The Reasons Why**  **Granting ROBERT H. CARLISLE**  **Request Would Be In The Public Interest; That Is, How It Woul**  **d Benefit The Public As A Whole:** Granting the present Petition will further the public interest b y allowing ROBERT H. CARLISLE to safely , efficiently , and economicall y perform search & rescue, aerial inspections, and video photograph y of real estate properties over certain areas of the United States. Additionally , use of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s will decrease congestion of the NAS, reduce pollution, crashes and accidents caused b y pilot error and provide significant benefits to the economy . Notabl y, the benefits of ROBERT H. CARLISLE ’ s proposed operation of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s will be realized wi thout implicating any privacy

issues. **1. The Public Will Benefit From Decreased Congestion o**  **f The NAS:** The BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UA ’ s are battery powered and serve as a safe, efficient, and economical alternative to the mann ed aircraft traditionally

utilized for search & rescue , aerial inspections, and to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UA would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UA S’ s do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting search & rescue and aerial video and photography missions would result in fewer aircraft that must be handled b y air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit From Th e Safety And Efficiency**  **o f The**  **BLADE CHROMA, YUNEEC TYPHOON**  **Q500, DJI PHANTOM 3**  **UAS’s:** Conducting search & rescue , aerial inspections, and aerial acquisitions with the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s, instead of manned aircraft, wi ll greatl y benefit the public by drastically

reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery

power and electric motors, the BLADE CHROMA, YUNEEC TYPHOON Q500 , DJ I PHANTOM 3 UAS ’ s produce no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typicall y utilized for search & rescue , aerial inspections, and aerial video and photography , while burning approximately 20
- 30 gallons per hour of leaded aviation fuel. The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA S’ s, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA S’ s are propelled by battery powered electric motors, rather than an internal combustion engine.**Page 16** 

By using the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s to perform search & rescue , aerial inspections, and aerial acquisitions, the subst antial risk to life and property

in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, th e BLADE CHROMA, has a maximum gross weight of 45.9 ounces while having a length of 15.7 inches, height of 9.5 inches and a maximum speed of approximately 3 0 mph. The YUNEEC TYPHOON Q500 has a maximum gross weight of 60 ounces while having a length of 22 inches, height of 8.3 inches and a maximum speed of approximate speed of 3 2 mph
. The DJ I PHANTOM 3 has a maximum gross weight of 45 .1 ounces, a length of 16.2 inches, width of 16.6 inches, height of 10.5 inches, and a maximum speed of appro ximately 33 mph . The UAS’s are equipped with four main rotors ; Driven b y Li thium Poly mer battery powered electric motors. , and with no fuel on board , has less ph ys ical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typi cally conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). **3 . Performing Aerial Video and Photography Operations With The**  **BLADE CHROMA,**  **YUNEEC TYPHOON Q500, DJI**  **PHANTOM 3 UAS**  **’ s Will Benefit The**  **Economy:** In addition to being safe and efficient, the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operations of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s will allow United States based companies remain competitive and contribute to growth of the U.S. economy. Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s is one such technology that not only

allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By op erating the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. econom y. Improved fi nancial performance of U.S. companies, through commercial use of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.**Page 17** 

**4 . There Are No Privacy Issues:**  Similar to the manned aerial acquisition flight operations that have been conducted for decades, ROBERT H. C ARLISLE ’ s proposed operation of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s will not implicate any privacy issues. Specificall y, the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s will be operated onl y in compliance with operating do cuments (i.e., Aerial Operations Manual, Monthly Maintenance Log, and BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 Instruction Manual s ) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. **E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Prov** **ided By The Rule From W**  **hich ROBERT H. CARLISLE**  **Seeks Exemption :**  1. Reasons Why

The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the siz e, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, ROBERT H. CARLISLE ’ s operation of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to user s of the NAS or the public, or otherwise pose a threat to national security . Specifically , FMRA Section 333 states the following, in part: (i) In General.
--Notwithstanding any other requirement of this subtitle, and not later than 180 day s after the d ate of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft s ys tems may operate safel y in the national airspace s ys tem before completion of the plan and rulemaking required b y section 332 of this Act or the guidance required b y s ection 334 of this Act. (ii) Assessment of Unmanned Aircraft S ys tems. -- In making the determination under subsection (a), the Secretary shall determine, at a minimum

— (a) which typ es of unmanned aircraft s ys tem (UAS), if any, as a result of their size, weight, speed, operational capability , proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to nati onal security; and (b) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft s ys tems identified under paragrap h (1).**Page 18**  ( iii ) Requirements for Safe Operation.
-- If the Secretary determines under this section that certain unmanned aircraft s ys tems may operate safel y in the national airspace sy stem, the Secretary shall establish requirements for the safe operation of such aircraft s ys tems in the national airspace s ys tem. In seeking this exemption, ROBERT H. CARLI SL E submits that the BLA DE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) The characteristics of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s; (b) The pilot certification requirement; and (c) The specific operating limitations. **a. The Specifications o f**  **The BLADE CHROMA, YUNEEC TYPHOON**  **Q500, DJI PHANTOM**  **3 UAS**  **’ s Demon**  **strate Its Safe Characteristics:** The BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability
. **(** i) Technical Specific ations of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s. The technical specifications of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s are set forth by the BLADE CHROMA, YUNEEC TY PHOON Q500, DJ I PHANTOM 3 Specifications and Data Sheets, attached. (ii) The BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area. The BLADE CHROMA, YUNE EC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s is provided in the BLADE CHROMA , YUNEEC TYPHOON Q500, DJ I PHANTOM 3 u ser m anuals. **(** iii) The BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s are designed f

or Automatic Return t o Home Point o r Hover In The Event of Loss o f The Control Li nk o r Navigation. When the Control Link i s lost, the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA S ’s do not reacquire control link data from the GCS, th e UA S will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the BLADE CHROMA , YUNEE C TYPHOON Q500, and DJ I PHANTOM 3 are set in the owner’s manuals , (iv) The BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 G CS and i ts Operation. A complete description of the operation and specifications of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 GCS and flight control software is provided in the User Manuals.**Page 19** 

**b. Flight Operations Of**  **BLADE CHROMA, YUNEEC TYPHOON Q500, DJI**  **PHANTOM 3 UAS**  **’ s Are Limited To The Line Of Sight Of A Certificated Pilot in**  **Command With A Safety Observer:**  ROBE RT H. CARLI SL E will only utilize pilots who have been trained and meet the requirements to act as a pilot in command (PI C) of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s. Additionally , a safety observer will assist all pilots during flight time. **c. Flights Of BLADE CHROMA, YUNEEC TYPHOON**  **Q500, DJI PHANTOM 3**  **UAS ’**  **s Will Be Conducted Pursuant To**  **Specific Operating Limitations:** In seeking this exemption, ROBERT H. CARLI SL E proposes to commercially operate BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s for the special purpose of conducting search & rescue , aerial inspections, and aerial video and photograph y over certain areas of United States, pursuant to the following specific operating limitations: **1.** Operations authorized by th is grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS ’ s weighing less than 55 pounds maximum gross weight. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. **2 .**  UAS operations under this exemption will be limited to conducting operations for the purpose of search & rescue , aerial inspections, and aerial video and photography
. **3 .**  The UAs may

not be flown at an indicated airspeed exceeding 35 mph
. 4 **.** The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved b y ATC. All altitudes reported to ATC must be in feet AGL. **5.** The UA must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s government issue d identification
. **6.** The use of first person view (FPV) b y the PI C or safety observer (SO) is not permitted. **7.** All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains V LOS capability . The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. **8.** The SO must not perform any other duties beyond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. **9.** The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy

e xists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the c onditions**Page 20**  and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrat or upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS
- 80) may

be contacted if questions arise regarding updates or revisions to the operating documents. **10.** Prior to each flight the PI C must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and th e UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records. **11.** Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records. **12 .**  The pre
- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. **13.** The operator must follow the UAS manufacturer’s aircra ft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. **14.** The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. **15.** Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. **16.** The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. **17.** The operat or may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emerg ency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may onl y be conducted during dedicated training sessions. During training, proficiency , and experience
- building flights, all persons not essential for flight operations are**Page 21**  considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. **18.** Operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. **19.** UAS operations may

not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. **20.** The UA may

not operate within 5 nautical miles of an airport reference point as denoted on a current F AA
- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the airport management must b e made available to the Administrator upon request. **21.** The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C. **22.** If the UA loses communicatio ns or loses its GPS signal, it must return to a pre
determined location within the planned operating area and land or be recovered in accordance with the operating documents. **23.** The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. **24.** The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. **25.** The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the op erator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. **26.** All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification markings in accordance with 1 4 C.F.R. part 45, Subpart C. Markings must be as large as practicable. **27.** Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. **28.** The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to th e Administrator or any law enforcement official upon request.**Page 22**  **29.** The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. **30.** The UAS may

not be operated b y the PIC from any moving device or veh icle. **31.** Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: ( a) Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediatel y and/or; (b ) The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permiss ion and the PI C has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; ( c ) Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). **3 2**  **.** All operations shall be conducted over private or controlled
- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorize d representative will be obtained for each flight to be conducted. **33.** Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA's UAS Integration Office (AFS
- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov
. **F . Reasons Why an Exemption Fr**  **om The Requirements Of Section 61.113(a) and (b)**  **Would Not Adversely Affect Safety**  **:** ROBERT H. CARLI SL E submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s unless that PI C has demonstrated, by meeting minimum flight
- hour and currency requirements, that the PI C is able to safel y operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’s in a manner co nsistent with the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering ROBERT H. CARLISLE ’ s proposed area of operations, the operating limitations set forth
- a

bove, and the airmanship skills necessary to safel y operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’s , ROBERT H. CARLISLE submits that the additional manned airmansh ip experience of a commerciall y certificated pilot would not correlate to the airmanship skills necessary for specific proposed flight operations.**Page 23** 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein. ROBERT H. CARLI SL E will not allow any PIC to operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’s unless that PI C has demonstrated, by meeting minimum flight
- hour requirements or the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’s training and currency requirements, that the PI C is able to safel y operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’s in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically , the PI C must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). **CONCLUSION** ROBERT H. CARLI SL E seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS ’ s commerciall y, without an airworthiness certific ate, for the limited purpose of conducting aerial video and photograph y over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing ROBERT H. CARLISLE to safely , efficiently , and economically operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’ s commerciall y within the NAS. WHEREFORE, in accordance with the Fe deral Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, ROBERT H. CARLISLE respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7( a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Robert H Carlisle to operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJ I PHANTOM 3 UAS ’s commerciall y for the purpose of conducting search & rescue , aerial inspections, aerial video and photography over certain areas of the United States.

Dated: November 2 4 , 2015 Submitted by ROBERT H. CARLISLE**Page 24** 



### APPENDIX **A :**  Technical Data Sheet : Blade Chroma Motor to Motor Distance: 15.7 in (400mm) Rotor Ty pe: Quadcopter Prop Diameter: 10.2 in (260mm) Approximate Flight Time: 30 minutes Battery : 11.1V 3S 6300mAh L i
- Po Height: 9.50 in (242mm) Weight: 45.9 oz (1.3 kg) Motor Ty pe: 4 × 780Kv Brushless Outrunner Control Link: 2.4GHz Video Link: 5.8GHz Video Link Range: 1,970 ft (600m) Satellite Navigation Sy stem: GPS, GL ONASS Completion Level: Ready
- to - Fly**Page 25** 

**Blade Chroma Features Smart	Mode**  Perfect for the first
- time drone fl yers

 Stick Relativity moves drone in whatever direction the control stick is pushed, no matter which way the nose is pointed  Creates a SAFE CircleTM barrier that prevents the aircraft from flying too close to you  Auto
-holds position and altitude when control sticks are released **AP	Mode** For more experienced drone pilots.

 Responds like a conventional drone without Stick Relativity  Gives you greater control authority by turning off the SAFE Circle  Keeps control response smooth so panning and tracking shots look great  Auto
-holds position and altitude when control sticks are released **Follow	Me	Mode** The b uilt
- in copilot

 Frees you to focus on lining up the perfect shot  Pan and tilt the camera while the drone follows  Drone follows at an altitude and distance you set **Tracking	Mode** Follow me

 Drone follows and keeps the camera pointed at whoever holds the ST
- 10+ controller  Drone follows at an altitude and distance you set  Resume full control at any time **Return	Home** Safe lan dings with the flip of a switch

 Returns the drone to its start
-up point and lands it for you  Great for first
- time flyers who aren’t ready to land themselves  Easy way t o regain visual contact if you lose sight in flight  Resume full control at any time  Activates automatically if controller signal is lost **Adjustable	Flight	Boundaries**

 Programmable flight boundaries limits flight to 400 ft AGL**Page 26** 

**Blade Chroma Camera** The inc luded CGO3 combines a high
- definition camera and 3
- axis stabilization gimbal into a single unit that captures steady aerial video and stills in unbelievable detail. All camera controls are placed within eas y reach on the included ST
- 10+ controller. **Camera features include:** 

 4K/30fps or 1080p/120fps video
 16MP photo
 No
- distortion lens

– eliminates fisheye effect
 Integrated, 3
- axis brushless stabilization gimbal
 Adjustable resolution and frame rate
 Adjustable settings for different lighting conditions
 Streams live video to the ST
- 10+ controller from as far as 600 meters
 Streams live video to multiple mobile devices within 90
- 120 meters *


### Blade	Chroma	ST **- 10	transmitter**  You don’t need a separate smart device with the ST
- 10+ controller. Every thing you need, including the camera controls and a touch
- screen video display is built right in.

 Large, 5 1⁄2 inch touch
- screen display with intuitive Android interface
 Display s live video and real
- time telemetry info like speed, altitude and battery voltage
 Clearly

marked swi tches and buttons
 Super
- simple flight and camera controls
 Slider switch for adjusting camera tilt
 Slider switch for adjusting drone speed**Page 27** 



### APPENDIX **B :**  **Technical Data Sheet :**  **Yuneec Typhoon Q500** 
**Ty phoon Aircraft** 

**Dimension**

**Flight Time up to 25 minute**  **s**
**Weight with Battery and Payload**  **60.0 oz (1700g)**
**Weight without Battery and Payload**  **40.0 oz (1130g)**
**Battery 5400m** **Ah 3S 11.1V LiPo (included)**
**Charger 3S 11.1V LiPo DC Balancing Sm**  **art Charger with AC Adapter (included)**

**Transmitter 10**  **- channel 2.4GHz wit**  **h 5.8GHz video downlink (included)**
**3 Flight Modes Sm**  **art (Follow Me and Watch Me), Angle and Hom e** 
**Maximum Flying Height Default 122m** **(400ft) above Ground Level (Adjustable via the Typhoon GUI) Page**  **28**

**Maximum Rotation Rate 65°/s** 
**Maximum Roll Angle 35°** 
**Operatin g Temperature**  **Range −5°C to 80°C** 
**Radio Control Frequency Band**  **2.4GHz**
**Max. Descent Speed 2m** **/s**
**Max. Flight Speed 8m** **/s**

**Gimbal Camera**
**Type CGO3** 
**Weight 6.9oz (195g)** 
**Focusing System Aerial Optimized Fixed Focus** 

**Field of View 115°** 

**Video Transmission Range**  **FCC Compliance: Up to 600m (1968.5 ft)**  **CE Compliance: Up to 300m (984.252 ft) with ST10**
**Video Resolution UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 30FPS** 

**— FULL HD: 1080p at**  **24/25/30/48/50/60/120FPS Photo Resolution**  **12 Megapixels Page**  **29**

**Storage (m em**  **ory) mi**  **croSD Class 10 ~ 4 to 128 GB**  **Control Angle Accuracy ±0.02°**  **White Balance Autom**  **atic or m anual settings**  **Transmission Band** 5.2GHz

– 5.8GHz **Input/Operating Voltage**  12V **Working Temperature** −10°C

– 50°C **Storage Tem perature**  −20°C

– 60°C **Angular Vibration Range**  ±0.02° **Control Range** Pitch: between −90° and 0° Yaw : between 0° and 360° **Microphone** Yes **Cam era Lens**  0.6in (14mm)/f2.8 (1.4in/35mm)

— No distortion **Sensor** 1/2.3 ′′ CMOS

Personal Ground St ation

**Dimensions**

**Type ST10+** 
**Operating System AndroidTM** 

**Number of Channels 10** 

**Control Transmission Range (Optim**  **um FCC Compliance: Up to 800m (2624.67 ft) CE Com** **pliance: Up to 400m (1312.34 ft) Warning: You Must Follow Local Laws and Maint**  **ain Visual Line Page**  **30**

**Conditions) of Sight of Aircraft at All Times** 

**Robust Radio Control Modulation**  **Yuneec Protocol**
**Video Link Frequency Band**  **5.8GHz**

**Video Transmission Range (Optim**  **um Conditions)**  **FCC Compliance: Up to 600m (1968.5 ft) CE Com pliance: Up to 300m** **(984.252 ft** **) Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Tim**  **es**
**Flight Systems Telemetry Data On**  **Screen Display Yes** 

**LED Backlit LCD Screen**  **Capacitive Multi -**  **touch 5.5 ′′** 
**Tactile (Vibrating) and Audible Feedback**  **Yes**

**Built -**  **in LiPo Battery Voltage / Capacity**  **3.6V/5200m Ah 18.72Wh** 

**Screen Resolution 854 × 480px** 

**Cam era Settings**  **White balance, light exposure, ISO, shutter speed, video resolution, FP S, record**  **video, take pictures Page**  **31**



### Appendix C: **Technical Data Sheet: DJI PHANTOM 3**  

### Performance Maximum Speed Ascent: 16.4' fps / 5 m/s Descent: 9.8' / 3 m
Hover Accuracy Vertical: ±3.9" / 10 cm Horizontal: ±3.3' / 1 m
Maximum Altitude Above Sea L evel: 19,685' / 6000 m Flight Time 23 minutes (depending on conditions) 

### Flight Control System
GPS Mode GPS / GL ONASS

Vision Positioning Frequency : 50 Hz Velocity Range: Below 26.2 fps / 8 m/s (6.6' / 2 m above the ground) Altitude Range: 11.8" to 118.1" / 30 cm to 300 cm Operating Range: 11.8" to 118.1" / 30 cm to 300 cm Operating Environment: Surface with clear pattern and adequate lighting (> 15 lux) 

### Transmitter Frequency 2.400 to 2.483 GHz**Page 32** 

Communication Distance 6561.7' / 2000 m (o utdoors and unobstructed) Receiver Sensitivity 1%PER: 101 dBm ±2 dBm
Transmitter Power EIRP: 20 dBm Working Current 1.2 A at 7.4 V
Connectivity 1 x USB ty pe A female for mobile device interface 1 x Micro
- USB female for firmware updates / assist ant software 1 x Charge port

Li ghtbridge Support Yes; compatible iOS or Android mobile device with USB required
Mobile Device Holder Compatibility : Tablet or smartphone Operating Temperature 32 to 104°F / 0 to 40°C 

### Camera

Sensor Make: Sony EXMOR Size: 1/2.3" Resolution: 12.76 MP (12.4 MP effective)

Lens Aperture: f/2.8 FOV: 94° Focal Length: 20 mm (35 mm equivalent) Elements: 9 Focus: 0 to ∞**Page 33** 

Photo Resolution Up to 12 MP (4000 x 3000)
ISO Range Video: 100 to 3200 Photo: 100 to 1600

Video Resolutions DCI4K (4096 x 2160) : 24p, 25p UHD 4K (3840 x 2160): 24p, 25p, 30p 1080p (1920 x 1080): 24p, 25p, 30p, 48p, 50p, 60p 720p (1280 x 720): 24p, 25p, 30p, 48p, 50p, 60p

Photo Modes Single Shot Burst Shooting: 3/5/7 shots Auto Exposure Bracketing (AEB): 3/5 Bracketed Frames at 0.7 EV Bias Time
- lapse

F ile Formats Video: MPEG
- 4 AVC/H.264 in MOV wrapper (up to 60 Mbps) Photo: JPEG, DNG RAW

Recording Media Ty pe: microSD/SDXC card up to 64 GB Format: FAT32 / exFAT **Note:** Class 10, UHS
- 1 or faster card required Operating Temperature 32 to 104°F / 0 t o 40°C 

### Gimbal
Number of Axes 3
- axis (pitch, roll, yaw) Control Range
- 90° to +30°**Page 34** 



### Motor Ty pe Brushless Recommended Takeoff Weight 10.6 oz / 300 g per axis
Maximum Tension 1.8 lb / 800 g per axis
Stator Size 0.9 x 0.5" / 23 x 12 mm Motor Velocity

Constant KV: 960 rpm/V Working Temperature 23 to 104°F /
- 5 to 40°C Weight 1.9 oz / 55 g 

### Flight Battery Chemistry Lithium
- poly mer Capacity 4480 mAh 68 Wh Configuration 4S Voltage 15.2 VDC Weight 12.9 oz / 365 g**Page 35** 

Maximum Charging Power 100 W Operating Temperature 32 to 104°F / 0 to 40°C
Charger Voltage: 17.4 VDC 100 W


### Mobile App

Name DJIPilot

Sy stem Requirements OS **:** iOS 8.0 or later; Android 4.1.2 or later Recommended Devices: iOS **:** iPhone 5s, iPhon e 6, iPhone 6 Plus, iPad Air (Wi
- Fi and cellular versions), iPad mini 2 (Wi
- Fi and cellular versions), iPad Air 2 (Wi
- Fi and cellular versions), iPad mini 3 (Wi
- Fi and cellular versions) (Note: Optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus) Androi d: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini Note **:** Additional devices may be compatible but have not yet been tested 

### General Operating Temperature 32 to 104°F / 0 to 40°C**Page 36** 

Dimensions Diagonal (Including Propellers): 23.2" / 590 mm Weight In cluding Battery and Propellers: 2.8 lb / 1.3 kg **Packaging Info** Package Weight 9.8 lb Box Dimensions (LxWxH) 15.4 x 14.3 x 8.3"**Page 37** 



### Appendix **D :**  Maintenance Log: (sample)



## Mainte **nance Log UAS: Chroma 1**  **Date: mm/dd/yy**  **Discrepancy: Corrective Action:**  **Tech /Date**  11/9/2015 Left Front prop has chip (sample) Replaced left front prop RC 11/10

Form: m101

11/15