US DepartmentofTransportation Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation

December 14, 2015 Carl T
. Cisler 315 E. Maple Centerville, lA
. 52544

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington DC 20590
Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR91
.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14CFR 91.203(a) and (b); 14CFR 91
.405 (a); 14CFR 91.407 (a) {1) 14CFR 91.409 (a)(1) and (2); 14CFR 91.417(a) and (b) Dear Sir or Madam : Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14CFR Part 11, Carl T. Cisler operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of designated UAS, provided such operations are conducted within and underthe conditions outlined herein oras may beestablished bythe FAA as required by Section 333. Thank you in advance foryourconsideration.Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 1. Aerial photographyand/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2
. Aerial video and/or photography for public and/or private use including television, public events, cinematography and newsgathering. 3. Aerial inspection/photography of residential/commercial structures under contract with the owners 

### or local government authority. 4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limitedtoelectrical power lines, wind turbines and cell towers. 5
. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

As described fully below, the requested exemption would permitthe operation ofdesignated UAS as set forth in this document under controlled conditions in the NAS that would be a)limited b) controlled c) predetermined and d) safe. Approval ofthisexemption would increase public awareness ofUAS operations and enhance safetyto aid in fulfillingthe Secretary of Transportation's (the FAA Administrator's) responsibilities to "
.... establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant Is: Carl T
. Cisler 

### Ph: 641 -437-1060 Email: carl@hometownonline.com Address: 315 E Maple Centerville, lA 52544

### Regulations fromwhichthe exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) 

### & (b) 14CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14CFR 91.103 14 CFR 91
. 109 14CFR 91.119 (c) 14CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) 

### & (b) 14CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14CFR 91.417 (a) 

### & (b) Carl T. Cisler will operate one or more ofthe Following model UAS: DJI Phantom 3 

### Aircraft Weight (including battery and propellers)-1280 g Diagonal size (including propellers)-590 mm MaxAscent Speed-S m/s Max Descent Speed-3 m/s Hover Accuracy-
• Vertical:+/- 0
. 1 m (when Vision Positioning is active) or+/- 0.5 m •Horizontal: +/ - 1.5 m Max Speed-16 m/s (A Til mode, no wind}MaxAltitude Above Sea Level-6000 m OperatingTemperature-0°C- 40°C GPS Mode-GPS/GLONASS Camera Sensor-Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) Lens-FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at oo ISO Range-100-3200 (video) 100-1600 (photo) ShutterSpeed-8s -1/8000s Image MaxSize-4000 x 3000 Still Photography Modes *Single Shot *Burst Shooting: 3/5/7 shots *Auto Exposure Bracketing (AEB) : 3/5 *Bracketed Frames at 0.7EV Bias *Time-lapse VIdeo Recording Modes Phantom 3 Professional •UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 •FHD: 1920x1080p 24/25/30/48/50/60 •HD: 1280x720p 24/25/30/48/50/60 Phantom 3 Advanced •FHD: 1920x1080p 24/25/30/48/50/60 •HD: 1280x720p 24/25/30/48/50/60 Supported SD Card Types* Micro SO *Max capacity: 64GB. Class 10 or UHS-1 rating required Max BitrateofVideo Storage**Phantom 3 Professional 60 Mbps **Phantom 3 Advanced 40 Mbps Supported File Formats• FAT32/exFAT
• Photo: JPEG, DNG •Video: MP4, MOV (MPEG-4 AVC/H.264} Operating Temperature-0°C- 40°C Gimbal Controllable Range-Pitch -90° tp +30° Stablllzation-3-axis (pitch, roll, yaw) Vision Positioning MaxVelocity-Less than 8 m/s (when 2 m above ground) Altitude Range-30 cm-300 em Operating Range-30 cm-300 em Operating Environment-Surfacewith clear pattern and adequate lighting (Lux> 

### 15} Remote Controller Operating Frequency-2.400 GHz-2.483 GHz Max Distance-2000m (outdoors and unobstructed} Video Output Port-USB Operating Temperature-0°C- 40°C Battery-6000 mAh LiPo 2S Mobile Device Holder-Fortablet or phone Receiver Sensitivity (1%PER)-101 dBm ±2 dBm Transmitter Power (EIRP) *FCC: 20dBm *CE: 16 dBmWorking Voltage-1.2 A @7.4 V Battery Charger Voltage-17.4 V Rated Power: Phantom 3 Professional 

### •lOOW Phantom 3 Advanced •57W Intelligent Flight Battery Capacity-4480 mAh Voltage-15.2 V Battery Type-LiPo 45 Energy-68 Wh Net Weight-365 g Max Flight Time-Approximately 23 minutes Operating Temperature--10°C to 40°C Max Charging Power-100 WGiven the small size ofthe UAS in scope and the controlled environment provided, the proposed operationswill adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests thatthe FAA grant the requested exemption. 

### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalentor higher level ofsafety because operationswill further enhance the safety ofthe persons and/or property using conventional aircraft
.These limitations and conditionsto which the applicant agrees to adhereto when conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 

### 1. The UAS will weigh significantly less than SSibs. It weighs less than 4 pounds with battery and camera. 2. The UAS, depending on the model i n operation, will have a maximum operating speed of no morethan SOmph. 3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). 4. Maximum flighttime for each operational flight will be depending on the UAS model in operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes offlight time whichever occursfirst. 5
. Flights will be operated at an altitude of no more than 400feet Above Ground Level (AGL) and not more than 200feet above an elevated platform from which filming is planned. 6. Minimum crew for each operation will consist ofthe UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate, Camera Operator (CO). 7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged a minimum of20 hours on the designated UAS.8. A safety briefing will be performed prior to each day's flights consisting ofall the days' production activities. 9. All flight activities will be logged. 10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 11. The flights will occur in Class G airspace no closer than a 5 mile radius ofthe geographic center/ Airport Reference Point {ARP) ofa tower controlled or uncontrolled airport. 12. Flights will not be closer than a 5 mile radius ofthe geographic center/ Airport. 13. The operator will file FAA Form 77111, or its equivalent, as modified in light ofthe requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 14. The operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as U.S. Department ofTransportation required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved. 15.The PIC and VO will have been trained in operation of UAS and receive up to date information for the particular UAS to be operated. 16. The PIC and VO will be able to communicate by voice and/or radio at all times. 17. Written and/orverbal permission and permitswill be obtained from territorial, state, county orcityjurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations. 18. Ifthe UAS loses communications with the remote controlleror loses GPS signal, the UAS will have the capability to return to a predetermined location within a designated location and land autonomously. 19. The UAS will have the capability to abort aflight in case of emergencies with an automated "Return Home and Land" function. 20. The UAS will have the capabilityto abort aflight in case of unpredicted obstacles, weather, or emergencies such as low battery.14C.F.R
. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirementsforthe issuance of airworthiness certificates as required by FAR §91
.203 (a) (1)
. Given the size and limited operating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act
.The Federal Aviation Act (49 U.S.C.§44701 (f)} and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirement foran airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate in the restricted environment and undertheconditions proposed will 

### be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed
.The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusivelywithin a secured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operatorand underthe requirements and in compliance with local publicsafety requirements. These safety enhancements provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14C
.F.R. Part 21, Subpart H. lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load. 14C.F.R. 

### § 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft neareach entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, the words"limited/' "restricted/' "light sport/' "experimental/' or "provisional/' as applicable 14 C
.F.R. § 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft orexperimental or provisionally certificated aircraft, the operator mustalso displayon that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, the words "limited/' "restricted/' "light sport/' "experimental/' or "provisional/' as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two inch letteringwill be impossible
.The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). US Department ofTransportation February 20, 2015
.The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45
.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14 C
.F
.R
. § 61
.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) 

### & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passengers or property for compensation or hire
. The proposed UAS operations may achieve an equivalent level ofsafetyas achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendantto theoperation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14CFR 61
. The PIC ofthe UAS will be, or be underthe direct supervision of, a FAA Certificated Private Pilot with current Third Class or higher medical certificate or avalid U
.S
. driver's license. It is believed that the operation and limitations set forth in the FOM will equate to the Safe operation ofthe UAS. 14 C
.F
.R. §91.7{a) : Civil Aircraft Airworthiness
.The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenanceand use ofsafety checklists priorto each flight, an equivalent level ofsafety will be provided. 14 C
.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) {2) provides: No person may operate a U
.S.registered civil aircraft
... 

### (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircrafta current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, oranycombination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room orcapacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual at the ground control point where the pilot flyingthe UAS will have immediate access to it
. 14 C
.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight
. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight
. 14 C
.F.R. §91.109: Flight Instruction. Section 91
.103 provides that no person may operate a civil aircraft (except a manned free balloon} that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates withthe aircraftvia radio communications
. The FAA has approved exemptions forflight training without fully functional dual controls fora number of aircraft and forflight instruction in experimental aircraft. The equivalent level ofsafety is provided bythe fact that neither a pilot nor passengers will 

### be carried in the aircraft and by the size and speed ofthe aircraft. 14 C
.F
.R. §91
.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than theminimums prescribed, provided the person operating the helicoptercomplies with any routeor altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations
. As set forth herein, the UAS will neveroperate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated morethan 200feet above the highest pointonthe structure
. Itwill however 

### be operated in a restricted area with security perimeter, where buildings and people will not

### be exposed to operations without their pre obtained consent. The equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UAS as well as the location where it Is operated. No flight will be taken withoutthe permission ofthe propertyowneror local officials. Because of the advance notice to the property ownerand participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far morethan the maximum SSibs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations ofthe UAS will ensure separation between these UAS operations and the operationsofconventional aircraft that must complywith Section 91
.119
. 14 C.F.R. §91.121 AltimeterSettings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set"
... to the elevation ofthe departure airport or an appropriate altimetersetting available before departure." 

### As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U
.S
. exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown on theGPS altitude indicator beforeflight. 14C
.F
.R. § 91.151(a): Fuel Requirements for Flight In VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless(considering wind and forecast weather conditions) there is enough fuel to flyto the first point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. The applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 30 minutes or 25% of battery power- whichever happens first. This restriction would be morethan adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate
.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs well underthe proposed 55 lb. limit and is operated without an onboard pilot. As such, there is no abilityor place to carry certification and registration documents orto display them on the UAS. An equivalent level of safety will be achieved by keeping these documents atthe ground control pointwhere the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. 14 C.F.R. §91.405 (a); 407 (a) {1); 409 (a) {2); 417(a) 

### & (b): Maintenance Inspections. These regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter
... ," and others shall inspect or maintain the aircraft in compliance with Part 43.Giventhat these sections and Part43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuantto the flight manual and operating handbook. An equivalent level ofsafety will be achieved because the UAS is very limited in size and 

### will carry a small payload and operate only in restricted areas for a limited period oftime
. Ifmechanical issues arise the UAS can land immediatelyand will be operating from no higherthan 400 feet AGL. The operator will ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover,the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operatorwill ensure thatthe UAS is in working order priorto initiatingflight and perform required maintenance needed
. Additional Information. The applicant, Carl T
. Cisler, believesthisexemption request and associated safety considerations adequately satisfy criteria provided in Section 333 ofthe Reform Act of 2012, providing sufficient justification forthe granting ofcommercial operations ofthe applicant's UAS. The applicant, Carl T
. Cisler requests your respective approval ofthis Section 333 exemption petition request. Thank you foryour attention in this matter. Please notify Carl T. Cisler ofyour actions, and or approvals. Thank You for your interest in this request.

315 E Maple Centerville, lA
. 52544 carl@hometownonline.com