Garth M. Bruce ONE VUE LLC 35714 SE 25th Street Fall City, WA 98024

September 23 rd , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

Re: Petition for Exemption Request to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR; 14 CFR 91.121; 14 CFR 91.151(b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) a nd (2); 14 CFR 91.417(a) and (b)

To Department of Transportation, Federal Aviation Administration:

Pursuant to Section 333 of the FAA Modern ization and Reform Ac t of 2012 and 14 CFR Part 11, Garth M. Bruce, ope rator of small Unmanned Aerial System (UAS), hereby applies for an exemption from the liste d Federal Aviation Regulations to allow commercial operation of a small UAS, so long as such operations are conducted within and under the conditions outlined herein or as my be established by the FAA as required by Section 333. Garth M. Bruce has a privat e pilot license (single engine land), completed multiple UAV training courses, and has 2 years two years of experience building and flying UAVs.

Commercial operation small UAS will have visible light cameras and multispectral sensors. They would be used for:

1. Aerial photography and/or vi deo for public and/or private use including agriculture, real estate, education, engineeri ng, and other related pr ofessional needs.

2. Aerial video and/or photography for search and rescue (SAR) operations as requested by county special services.

Background

The requested exemption would permit the operation of a DJI Phantom 2 Vision Plus, DJI Inspire I, and th e senseFly eBee UAVs under controlled conditions in the NAS. Garth M. Bruce will use experienced technicians to perform maintenance on the UAVs using the methods, techniques, and practices stat ed in the operating documents for the DJI Phantom 2, and Inspire I, and senseFly eBee instruction manuals. Garth M. Bruce will also document and store all maintenance records for the UAVs listed above.

The DJI and eBee products use a Ground C ontrol Station (GCS) utili zing on an electronic tablet or smart phone system. All system ar e under 55lbs and in normal conditions they operate at speeds of no more than 56 M ph. All of the UAVs operate using Lithium Polymer batteries to power el ectric motors. They adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues.Granting the requested exemption is in the public interest given the potential reduction of environmental impact from reduced noise, emissi ons, energy, and increased efficiency.

Name and Address of Petitioner

Garth M Bruce 35714 SE 25 th Street Fall City, WA 98024 425.466.8270 garth@one-vue.com

Regulations from which the exemption is requested

14 CFR 61.113(a) & (b) 14 CFR 91.7 (a) 14 CFR 91.121 14 CFR 91.151 (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (1) & (a) (2) 14 CFR 91.417 (a) & (b)

1. Extent of Relief Garth M Bruce se eks from 14 CFR 61.113(a) and (b) Relief from Section 61.113(a) a nd (b) entitled Private pilo t privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as we ll as a current and valid airman medical certificate, and who has met certain flight -hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested sin ce the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

A pilots license is useful in understanding the airspace and commercial activities in 14 CFR 61 but the operation and limitations set forth in the FOM will equate to the safe operation of the all flights of the DJI Phan tom 2 Vision+, DJI Inspire 1, and senseFly eBee. Garth M Bruce submits that an equivale nt level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+, Inspire I, or senseFly eBee UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating the PIC is able to safely operate the UASs in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, maintain ing appropriate dist ances from people, vessels, vehicles and structures.

Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement or other appropriate governmental agencies when needed.2. Extent of Relief Garth M Bruce seeks fr om 14 C.F.R. §91.7( a): Civil Aircraft Airworthiness.

The regulation requires that no person may ope rate a civil aircraft unless it is in airworthy condition. As there are no airwor thiness certificates i ssued for the UAVs no standard will exist for determining airworth iness. Given the size of the aircraft and use of safety checklists prior to each flight an equivalent leve l of safety will be provided.

Garth M Bruce will ensure that the DJI Phantom 2 Vision+, Inspire 1, and senseFly eBee are in airworthy cond ition based upon the compliance with the Maintenance Logs and Instruction Manuals prior to each flight.

3. Extent of Relief Garth M Bruce seeks fr om 14 C.F.R. §91.121 Altimeter Settings.

This requirement specifies an aircraft to maintain a cruising altitude by setting the altimeter to the elevation of the departure airport or an appropriate altimeter setting available before departure. An equivalent level of safety will be achieved by the operator referencing the barometric pressu re sensor and GPS indicators which are provided to the ground station software via the data link. The UAVs flight data will be used to confirm the altitude of the launch site before flight.

4. Extent of Relief Garth M Bruce seek s from 14 C.F.R. § 91.151(b): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (b) prohibits an individual fr om beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first poi nt of intended landing, and, assuming normal cruising speed – (1) During the day, to fly afte r that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The LiPo batteries powering the UASs provide a minimum of 18 minutes of consistent flight time, 13 minutes to the first intended landing area, and 5 minutes following. Given the limitations of the UASs, the flight area and flight time are restricted. Garth M Bruce will safely ope rate the UAVs during daylight hours in visual meteorological conditions and under vi sual flight rules with enough battery power to fly to a designated area and allow for a return to the intended landing point at a normal cruising speed.

5. Extent of Relief Garth M Bruce seeks fr om 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (1) and (a) (2); 417(a) & (b ): Maintenance Inspections.

Since these sections only apply to aircraft with an airworthiness certificate, Garth M Bruce requests relief from th ese Sections given the DJI Phantom 2 Vision+, Inspire 1, and senseFly eBee do not require airworth iness certificates. Accordingly, Garth M Bruce will use trained technicians to perfor m maintenance, alterations, or preventive maintenance on the UASs as outlined in the Operations Manuals, Maintenance Logs, and Instruction Manuals. Garth M Bruce will document and maintain all maintenance records for the UAVs listed above to provi de the equivalent level of safety.UAS Information

Small UASs to be used are as follows but not limited to providing they are within the scope of the exemption granted by the FAA:

1. DJI Phantom 2 Vision Plus

• Weight (Battery & Prope llers Included) – 2.74 lbs.

• Hover Accuracy (Ready to Fly) –V ertical: 24 ft; Ho rizontal: 7.5 ft

• Max Yaw Angular Velocity – 2000/s

• Max Tilt Angel – 350

• Max Ascent Speed – 18 ft/s

• Max Descent Speed – 6 ft/s

• Max Flight Speed – 45 ft/s

• Battery

 DJI 5200mAH LiPo

 Current – Static: 750mA; Dynamic: 900mA

• Transmitter Frequency – 5.728GHz –5.85GHz

• Communication Distance (unobstruc ted) – FCC Compliance: 800m

• Transmitter Power – FCC Compliance: 100mW

• Working Voltage – 120mA@3.7V

• Range Extender Frequency – 2412-2462MHz

• User Manual - http://www.dji.com/ product/phantom-2-vision/download

2. DJI Inspire I

• Weight (Battery Included) – 6lbs 7.5291oz (2935g)

• Hovering Accuracy (GPS Mode) – Ve rtical: 0.5m; Horizontal: 2.5m

• Max Tilt Angle - 350

• Max Ascent Speed – 5m/s

• Max Descent Speed – 4m/s

• Max Speed – 22m/s

• Max Flight Altitude – 4500m

• Max Flight Time – Appr oximately 18 minutes

• Operating Temperature Range – 140F to 1040F (-100C to 400C)

• Dimensions – 17 1 ⁄

4” x 17 3 ⁄

4” x 12”

• Transmitter Frequency – 5.728-5.850GHz; 2.400-2.483GHz

• Communicating Distance (unobstructed) – 2000m

• Output Power – 9W

• Operating Temperature Range - 140F to 1040F (-100C to 400C) 2.2.4.6

• User Manual - http://www.dji. com/product/inspire-1/download

3. senseFly eBee

• Weight (includes camera) - Approx. 0.71 kg (1.56 lbs)

• Wingspan - 96 cm (38 in)

• Material - EPP foam, carbon structure & composite parts

• Propulsion - Electric pusher propelle r, 160 W brushless DC motor

• Battery - 11.1 V, 2150 mAh

• Maximum flight time - 45 minutes

• Nominal cruise speed - 40-90 km/h (11-25 m/s or 25-56 mph)

• Radio link range - Up to 3 km (1.86 miles)• Wind resistance - Up to 45 km/h (12m/s or 28 mph)

• Transmitter Frequency - 2.4 GHz

• Communicating Distance - approx. 1 km (Certification: CE, FCC)

• Multi-drone operation - Yes (inc. mid-air collision avoidance)

• Automatic 3D flight planning

• Linear landing accuracy - Approx. 5 m (16.4 ft)

• Flight planning & control – eMotion

• User Manual - https://www.sensefly.com/fileadmin/user _upload/sensefly/documents/manuals/Ext ended_User_Manual_eBee_and_eBee_Ag_v16.pdf

Maintenance Log

Maintenance Log UAV: Description of Inspectio ns, Tests, Repairs, Alterations By: Date Date Time

Conclusion

Thank you for the consideration of these exemptions.

Sincerely,

Garth M. Bruce