Cambria Hobby, LLC 1 December 11, 2015
U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Section 333 of the FAA Reform Act Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, CAMBRIA HOBBY, LLC, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its Small UnmannedAircraft Systems (“sUAS”) CAMBRIA HOBBY, LLC UAS Platform, a DJI Series Phantom 2, 3, Inspire 1 and Skyhunterfoam air plane. CAMBRIA HOBBY, LLC plans to engage in commercial UAV services to residential, commercial, industrial, and governmental clients in the following applications:

• Aerial Videography & Photography, Mapping, and Aerial Assessments;

• Agriculture Surveys and Assessments;

• Real Estate Videography & Photography;

• Damage Assessments Due to Natural Disasters;

• Public Safety Mapping, Inspections, and Assessmentswith Search and Rescue; and,

• Wind Farm Inspections.

• Power Line Inspections. 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. As detailed in this document, the requested exemption would permit the operation of sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access, and 4) would provide safety enhancements to the already best practices and safety protocols followed by CAMBRIA HOBBY, LLC. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the National Airspace System.” Section 333(c) of the Reform Act.
**The name and address of the applicant is: CAMBRIA**  **HOBBY , LLC**  2118 Foster Ave. Ventura, CA. 93001 Phone (714) 794

-4164 Mark Mondello, Owner and Operator Email:mark@cambriahobby.comCambria Hobby, LLC 2 **Regulations from which the exemption is requested: 14 CFR Part 21**  **14 CFR 45.23(b) 14 CFR 61.113 (a) & (b)**  **14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)**  **14 CFR 91.103 14 CFR 91.109**  **14 CFR 91.119 14 CFR 91.121**  **14 CFR 91.203 (a) & (b)**  **14 CFR 91.405 (a) 14 CFR 407 (a) (1)**  **14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)** 



### 1. **STA TUTORY** **AU THORITY FOR EXEMPTIONS**  The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702

-44716 ofthis title ifthe Administratorfinds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1). Section 333(b) of

the Reform Act assists the Secretary in determining whether sUAS may operate in the National Airspace System (NAS) without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider:

• The sUAS’s size, weight, speed, and operational capability;

• Whether the sUAS operates within the visual line of sight of the operator

• Whether the sUAS operates outside of highly populated areas and away from close proximity to airport Reform Act §333(a). If the Secretary determines that a sUAS “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c). CAMBRIA HOBBY, LLC sUAS are multirotorvehicles and foam fixedwing RC air craftweighing 55 or fewer lbs. including payload. They operate under normal conditions at a speed of no more than 85 knots. The sUAS will only operate within the Pilot’s visual line of sight (VLOS) and will only operateCambria Hobby, LLC 3 within the predetermined flight plan boundaries. Such operations will insure that the sUAS will “not create a hazard to users of the national airspace system or the public.” Reform Act Section 333 (b). Given the small size ofthe sUAS involved and the restricted and controlled environment within which theywill operate, our applicationfalls squarelywithin the zone of safety (an equivalent level ofsafety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUAS to commence immediately.Also duetothe small size of the sUAS and the low altitudes and restricted areas in which the sUAS will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, the grant ofthe requested exemptions is in the public interest. Accordingly, CAMBRIA HOBBY, LLC respectfully requests that the FAA grant the requested exemption in a timely manner.


### 2. **PUBLIC INTEREST** This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. By granting an exemption the FAA will fulfill Congress’s intent of allowing UAS to operate with significant safety precautions in low risk environments. The use of sUAS on a Public and Private applications can significantly reduce the risk while inspecting, surveying, or monitoring missions. sUAS can inspect, photograph, and collect data on hard to get to areas that otherwise would require worker inspection. Additionally, sUAS could replace the use of helicopters and small aircraft to monitor sites. The sUAS we propose to fly in this application are under five pounds, and carry no combustible material on board, as opposed to the much larger conventionally powered small aircraft. Shif ting to sUAS from helicopters presents a marked safety increase for our workers and the public. Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy used for aerial imaging and data collection overa construction site. OursUAS use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of small aircraft that are many hundreds of times heavier.



### 3. **EQUIVA LENT LEVEL OF SA** **FETY** CAMBRIA HOBBY, LLC proposes that the exemption requested herein apply to sUAS that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe protocolsCambria Hobby, LLC 4 followed on construction sites and imaging and surveying operations conducted with helicopters and other conventional aircraft.

CAMBRIA HOBBY, LLC will be bound by the following limitations when conducting its sUAS operations under an FAA issued exemption:


### 1. The sUAS will be less than55 pounds. 

### 2. Mission Planning will be conducted prior to each Mission 

### 3. Flights will be operated within visual line of sight (VLOS) ofthe Pilot, who will work with a Visual Observer (VO), as required. 

### 4. Maximum total flight time for each operational flight will be 20 minutes. The UAS calculates battery reserve in real time, and will return to its ground station with at least 20% battery power reserve, should that occur prior to the 15 minute limit. 

### 5. Flights will never exceed 400 feet, above the ground level (AGL). 

### 6. Crewfor each operation will consist ofa sUAS Pilot andVOwhowill keep the sUASwithin their VLOS at all times. 

### 7. The sUAS Pilot will be a minimum holder of a Private Pilot Certificate with a Class 3 Medical or Issued State Driver’s License. 

### 8. The sUAS will only operate within a planned flight profile, unless conditions warrant a different path due to changing conditions or environment. 

### 9. All flights will be conducted within a set of weather constraining guidelines. 

### 10. If Flights are will in 5NM of a designed FAA Airports in Airport/Facility Directories (AFD), the PIC will contct the airport control tower

. 

### 11. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s flights. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 

### 12. All flights will have prior consent from property owners or representatives. 

### 13. Pilots will have been trained in operation of UASs generally and received up-to

-date information on the particular UAS. 

### 14. All required permissions and permits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate agencies. 

### 15. If the sUAS loses communications or loses its GPS signal, it will have capability to enter “loiter mode” and hover, reestablish satellite connection, and return to a pre- determined location within the flight plan’s controlled airspace.



### 4. **DESCRIPTION OF SPECIFIC REGULA TIONS**  **14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command** Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUASwill not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the Pilot operating the aircraft to have completed a sUAS minimum of 100 Cycles of Landing and Takeoff with a minimum of 20 Flight Hours in an aircraft craft. Unlike aCambria Hobby, LLC 5 conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board

. DJI UAS Platforms are also operated by an autopilot, which greatly reduces the danger of human error. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in a predetermined route and flight plan. The sUAS to be operated hereunder is less than 10 pounds fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquidfuels, and operates exclusively within a secured area as set out in theflight plan. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the flight plan’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is currently done on active construction sites. The FAA will have advance notice of all operations. The risks associated with the operation of the sUAS are therefore diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, and allowing operations ofthe sUAS as requestedwith a Pilotwho has metthe minimum requirements established by 14 CFR §61.113 (a) & (b). **14 CFR 91.103: Preflight A ction**  This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An exemption is needed from this requirement as the Pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Pre

-flight Checklist. These actions will provide an equivalent level of safety. **14 CFR 91.119: Minimum Safe A ltitudes**  Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided that the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing,whichwill typically operate at altitudes of200AGL, so an exemption may be needed to allow such operations. The sUAS will never operate at altitude higher than 400 AGL and will have a mission flight profile, where buildings and people will not be exposed to operations, without their pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, speed ofthe sUAS, as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and any onsite personnel as outlined in the flight plan, all affected individualswill be aware of the planned flight operations. Unlike flight operations with aircraft or rotorcraft weighing far more than the maximum 10 lbs. proposed herein, our sUAS will not carry flammable fuel. In addition, the low

-altitude operations of the sUAS will ensure separation between sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.Cambria Hobby, LLC 6 **14 CFR 91.121: A ltimeter Settings**  This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed.An equivalent level of safety will be achieved by the operator, pursuant to the Pre

-flight and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. **14 CFR 9 1.151 (a): Fuel requirements for flight in VFR conditions**  Section 91.151 (a) outlines fuel requirements for beginning a flight in Visual Flight Rules (VFR) conditions. Our sUAS is limited to operations in sterile and controlled environments and has a limited range and flight time which require an exemption from 14 CFR 91.151(a). The battery powering the sUAS provides approximately 20 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. CAMBRIA HOBBY, LLC believes that an exemptionfrom 14 CFR §91.151(a)falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small sUAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough battery reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power (as determined by the onboard monitoring system and the Pilot), whichever happensfirst. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. **14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections** These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to CAMBRIA HOBBY, LLC. Maintenance will be accomplished by the operator pursuant to the sUAS’s operations manual. An equivalent level of safety will be achieved becauseCambria Hobby, LLC 7 these small sUAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and will be operating from no higher than 400 feet AGL. The Pilot will ensure that the sUAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the Pilot isthe person mostfamiliarwith the aircraft and best suited to maintainthe aircraft in an airworthy condition to provide the equivalent level of safety. Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemptionfrom thefollowing rules: 14 CFR §21, subpart H; 14 C.F.R 45.23(b);14 CFR §§ 61.113( a) & (b);91.7(a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in construction operations. Approval of exemptions allowing commercial operations of sUAS in the public/private sector enhances safety while reducing risk. Manned aircraft monitoring and surveying creates a greater risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing fewer than 10 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of small sUAS, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground, structures, and people. **Privacy** All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUAS in public/private sector as defined above Sincerely,

Mark Mondello Owner and Operator