1

September	2,	2015

Patrick	Ward

GreenLeaf	Solutions

P.O. Box	1757

Snoqualmie,	WA		98065

Email:	patrickward@yahoo.com

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	2012

References:

1) FAA	Exemption	No.	11138,	Regulatory	Docket	No.	FAA-2014-0481	in	the	

matter	of	the	petition	of	DOUGLAS	TRUDEAU

2) FAA	Exemption	No.	11136,	Regulatory	Docket	No.	FAA– 2014–0508	in	the	

matter	of	the	petition	of	ADVANCED	AVIATION	SOLUTIONS	LLC

3) FAA	Exemption	No.	11080	Regulatory	Docket	No.	FAA-2014-0355	in	the	

matter	of	the	petition	of	FLYING	CAM	INC

Dear	Sir	or	Madam,

In	accordance	with	the	FAA’s	Guidelines	for	Submitting	a	Petition	for	Exemption

under	section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012,	I	Patrick	Ward of	

GreenLeaf	Solutions,	referred	to	hereafter	as	the	petitioner,	request	exemption	from	

the	following	sections	of	Title	14,	Code	of		Federal	Regulations	§§

61.113(a);	61.113(b);	91.119(c);	91.121;	91.151(a);	91.405(a);	91.407(a)(1);	

91.409(a)(1);	91.409(a)(2);	91.417(a)	&	(b);

In	order	to	operate	small	unmanned	aircraft	systems	(UAS)	commercially	in	

airspace	regulated	by	the	Federal	Aviation	Administration	(FAA)	for	the	purposes	of	

aerial	photography,	cinematography,	videography,	mapping,	crop	surveying,	

inspections, and	other	flight	operations	that	could	be	performed	safely	and	more	

cost	effectively	with	the	use	of	small	UAS	at	low	altitude	within	the	U.S.	national	

airspace	system	as	compared	to	a	manned	aircraft.	 Operations	will	be	performed	

only	at	the	request	of	and	with	the	authorization	and	permission	of	clients	or	their	

authorized	agents	in	order	to	facilitate	commerce	and	raise	awareness	of	the	

beneficial	uses	of	small	unmanned	air	systems.	 So	long	as	such	operations	are	

conducted	within	and	under	the	conditions	outlined	herein	or	as	may	be	established	

by	the	FAA	as	required	by	Section	333.	The	conditions	identified	and	proposed	by

the	petitioner	are	drawn	from	references	1-3.
2

The	FARs

The	petitioner seeks	exemption	from	the	above-mentioned	FARs	for	the	following

reasons;

61.113(a)	&	(b)	The	petitioner	requests	relief	in	order	to	facilitate	the	utilization	of	

pilots,	who	hold	a	PRIVATE	PILOT	(or	greater)	certificate.	Any	pilots	operating	

under	this	exemption	would	be	required	to	comply	with	any	conditions	as	set	forth	

and	in	a	similar	fashion	to	the	previously	granted	exemptions.

91.119(c) As	discussed	in	Exemption	11138	(DOUGLAS TRUDEAU),	operations	

conducted	closer	than	500	feet	to	the	ground	may	require	that	the	UA	be	operated	

closer	than	500	feet	to	essential	persons,	or	objects	that	would	not	be	possible	

without	additional	relief.	The	petitioner	requests	modification,	waiver or	exemption	

and	clarification	concerning	the	terms	“congested	areas”	and	“densely	populated”.		

The	petitioner	requests	waiver	for	this	condition	to	allow	reasonable	and	

responsible	operations	in	areas	of	subdivisions	and	neighborhoods	if	required.

91.121 As	discussed	in	Exemption	11138	(DOUGLAS	TRUDEAU)	is	inapplicable	

since	the	UAS	does	not	have	an	altimeter	and	instead utilizes	electronic	GPS	with	a	

barometric	sensor	for	altitude	information.

91.151(a) As	discussed	in	Exemption	11136	(ADVANCED	AVIATION SOLUTIONS	

LLC)	prior	relief	has	been	granted	for	manned	aircraft	to	operate	at	less	than	the	

prescribed	minimums,	including	Exemption	Nos.	2689, 5745,	and	10650.	 In	

addition,	similar	UAS-specific	relief	has	been	granted in	Exemption	Nos.	8811,	

10808,	and	10673	for	daytime,	VFR	conditions.	 The	UAS	provides	battery	power	

remaining	in	percent	to	the	PIC.	 The	UA	batteries	provide	approximately	25	

minutes	of	powered	flight.	 Information	provided	in	the	operating	documents

discusses	procedures	regarding	remaining battery	power	management.	Those	

documents	contain	a	condition	in	which	the	PIC	will	initiate	a	landing	procedure	

when	battery	remaining	reaches	a	specified	level.	 Given	the	limitations	on	proposed	

operations	and the	location	of	those	proposed	operations, the	FAA	found	that	a	

reduced	minimum	power	reserve	for	flight	in	daytime	VFR	conditions	was	

reasonable.

91.405(a);	91.407(a)(1);	91.409	(a)(1)	&	(2);	91.417(a)	&	(b) As	discussed	in

Exemption	11138	(DOUGLAS	TRUDEAU),	The	petitioner	proposes	to	inspect	and

ensure	that	the	UAS	is	in	a	condition	for	safe	flight	in	accordance	with	the	operating	

documents. The	FAA	found	that	adherence	to	the	petitioner’s	operating	documents	

and	the	conditions	and	limitations	specified,	describing	the	requirements	for	

maintenance,	inspection,	and	recordkeeping,	were	sufficient	to	ensure	that	safety	

would	not	be	adversely	affected.
3

The	UAS

UAS	Model	1:	The	DJI	Phantom	3	series	(standard,	advanced,	professional)	is	a	

highly	successful	consumer	grade	small	rotorcraft	in	the	quad	copter	configuration	

with	an	advertised	weight	of	less	than	3	pounds	(1,280g)	designed	primarily	to	

carry	aloft	a	high	definition	camera.	It	has	an	advertised	maximum	speed	of	less	

than	30	knots	(16m/s)	and	a	maximum	climb	rate	of	less	than	1200	feet	per minute	

(6m/s).	It	is	powered	by	four	electric	motors	with	a	distance	between	motors	of	less	

than	14	inches	(350mm)	It	utilizes	an	internal	inertial	measuring	unit	(IMU)	with	

integrated	barometric	sensor	augmented	with	global	positioning	system	(GPS)	to	

maintain	its	geospatial	orientation	and	position.	It	is	controlled	primarily	through	

an	FCC	certified	radio	control	(RC)	unit.	Real	time	video	and	telemetry	information	

is	transmitted	back	to	a	ground	control	station	allowing	the	operator	and/or	PIC	to	

monitor	battery	level,	GPS	signal	strength,	altitude	(AGL),	distance	from	PIC,	camera	

imagery,	and	control	camera	angle.	It	has	failsafe	modes	of	operation	for	either	loss	

of	RC	or	GPS	signal.	Battery	life	limits	flight	times	to	approximately	23 minutes.	The	

onboard	flight	controller	will	warn	the	pilot	via	telemetry	and	external	lighting	cues	

before	reaching	a	low	battery	state.	An	automatic	termination	of	flight	and	landing	

will	be	initiated	when	the	battery	reaches	a	predetermined	low	state.	It	is	

anticipated	that	flights	will	usually	last	less	than	15	minutes.	More	information	is	

available	at	http://www.dji.com/products/phantom-3-series

UAS	Model	2:	The	DJI	Phantom 2 Series	(standard,	vision,	vision	plus)	is	a	highly	

successful	consumer grade	small	rotorcraft	in	the	quad	copter	configuration	with	an	

advertised	weight	of	less	than	3	pounds	(1,242g)	designed	primarily	to	carry	aloft	a	

high	definition	camera.	It	has	an	advertised	maximum	speed	of	less	than	30	knots	

(15m/s)	and	a	maximum	climb	rate	of	less	than	1200	feet	per	minute	(6m/s).	 It	is	

powered	by	four	electric	motors	with	a	distance	between	motors	of	less	than	14	

inches	(350mm)	It	utilizes	an	internal	inertial	measuring	unit	(IMU)	with	integrated	

barometric	sensor	augmented	with	global	positioning	system	(GPS)	to	maintain	its	

geospatial	orientation	and	position.	It	is	controlled	primarily	through	an	FCC	

certified	radio	control	(RC)	unit.	 Real	time	video	and	telemetry	information	is	

transmitted	back	to	a	ground	control	station	allowing	the	operator	and/or	PIC	to	

monitor	battery	level,	GPS	signal	strength,	altitude	(AGL),	distance	from	PIC,	camera	

imagery,	and	control	camera	angle.	 It	has	failsafe	modes	of	operation	for	either	loss	

of	RC	or	GPS	signal.	Battery	life	limits	flight	times	to	approximately	17	minutes.	 The	

onboard	flight	controller	will	warn	the	pilot	via	telemetry	and	external	lighting	cues	

before	reaching	a	low	battery	state.	 An	automatic	termination	of	flight	and	landing	

will	be initiated	when	the	battery	reaches	a	predetermined	low	state.	 It	is	

anticipated	that	flights	will	usually	last	less	than	15 minutes.	 More	information	is	

available	at http://www.dji.com/products/phantom-2-series .
4

Risk	mitigation

The	petitioner	has	reviewed	FAA	exemptions	reference’s	1-3	Conditions	and	

Limitations	section	and	believes	that	the	procedures specified	therein	are	

reasonable	and	will	be	utilized	in	order	to	manage	and	mitigate	risk	and	ensure	

public	safety.	A	preflight	checklist	will	be	developed	and	employed	to	ensure	that	

the	UA	airworthiness	will	be	verified	before	launch.	Airworthiness	will	be	

maintained	by	performance	of	routine	inspections	before	each	flight,	maintaining	

flight and	maintenance	logs	to	record	time	on	failure-prone	components.

The	petitioner	request	that	in	a	manner	similar	to	reference	3,	he	be	allowed	to	

operate	within	5	miles	of	an	airport	provided	that;

“The	UA	may	not	operate	in	Class	B,	C,	or	D	airspace	without	written	approval	

from	the	FAA.	The	UA	may	not	operate	within	5	nautical	miles	of	the	

geographic	center	of	a	non towered	airport	as	denoted	on	a	current	FAApublished	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	by the	operator’s	COA.	The	letter	of	agreement	with	the	

airport	management	must	be	made	available	to	the	Administrator	upon	

request.”

Operations	within	5	miles	of	an	airport	are	not	anticipated	to	be	routine	but	the	

petitioner	is	requesting	a	mechanism	to	facilitate	such	activities	without requesting	

a	new	and	separate	exemption(s)	should	the	need	arise.	Operations	within	class	B	

airspace	are	not	requested	due	to	the	lack	of	mode	C	transponder.

Public	interest

Use	of	the	UAS	in	lieu	of	a	manned	aircraft	would	enhance	safety	and	reduce	the	

environmental	impact	as	compared	to	similar	operations conducted	with	manned	

aircraft	of	greater	proportions,	carrying	a	crew	and	flammable	fuel.	 Additionally,	

use	of	the	UAS	in	order	to	facilitate	commerce could	lead	to	economic	growth.		

Operations	for	this petition	will	enable	service	for	property	owners	or	their	

designees	seeking	an	enhanced	perspective	for	characteristics,	amenities,	and	

benefits	of	their	desired	photographic	subjects	that	cannot	be	displayed	through	

ground	level	videography/photography.	 Aerial	photography	is	a	valuable	marketing	

tool	that	can lead	to	increased	commerce	and	enhance	personal	photography.	 Crop	

surveying	applications	could	lead	to	decreased	use	of pesticides	and	fertilizer	and	

conservation	of	water	as	well	as	increased	crop	yields	and	decreased	costs.	 Aerial	

surveying	and	inspections	can	increase	work	site	efficiency,	improve	volumetric	

estimations	and	reduce	risks.	 The	petitioner	will	provide	clients	with	photographic	

data	for	these	purposes	on	a	‘for	hire’	basis	acting	as	an independent	contractor.	A	

visual	observer	will	be	utilized.	 Liability	insurance	will	be	obtained	commensurate	

with	the	granting	of	this	request	for	exemption.	 Flight	data	including	UA	flight	time,	

Control	Unit	operation	time,	incident,	accident,	and	details	concerning	any	
5

deviations	from	normal	operations	will be	available	to	FAA	for	use	in	collecting	data	

regarding	the	use	of	UAS	as part	of	this	application.	This	data	may	be	submitted	to	

FAA	via	traditional	means,	e.g.	COA	Monthly	Reports,	or	other	means	as	required.

Conclusion

The	petitioner	is	requesting	this	exemption	for	the	purposes	of	“aerial photography,	

cinematography,	videography,	mapping,	crop	surveying,	inspections	and	other	flight	

operations”.			The	reason	for	such	a	general	and	broad	based	request	is	that	the	

petitioner	wishes	to	utilize	a	business	strategy	of	horizontal	integration	and	

maximize	economies	of	scope	in	order	to	capitalize	on	opportunities	as	they	may	

arise in	the	future	without	the	long	turnaround	time	associated	with	additional	

exemptions.	 The	petitioner's	business	model	is	based	on	the	idea	of	offering	ad	hoc	

small	UAS	services	to	individuals	or	companies	who	wish	to	employ	these	services	

as	a	safe, effective,	and	legal	option	to	enhance	their	business or	hobby.		The	

primary	purpose	of	seeking	this	exemption	is	to	obtain	the	capability	to	offer	those	

services	while	remaining	in	compliance.	

Adding	to	the	level	of	safety	and	experience	in	these	operations,	the	petitioner	has	

over	20	years	of	experience	in	the	radio	control	model	aircraft	hobby,	has	a	current	

FAA	class	3	medical,	and	is	an	FAA	licensed Private	Pilot.

Respectfully	submitted,

Patrick	Ward

GreenLeaf	Solutions