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George W. Inskeep Sonoma, CA

– Section 333 Exemption Petition September 4, 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 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a ) (1); 91.409(a) (2); 91.417(a)&(b) To the Administrator, I, George W. Inskeep , am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, George W. Inskeep, an owner and ope rator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, George W. Inskeep , may operate my small ultra

- lightweight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federa l Aviation Administration (“FAA”). As described herein I, George W. Inskeep , am a n employee of a small business within the State of California ; experienced in flying hobby type helicopters and aircraft for recreational purpose s and am a n FAA certificated commercial airplane pilot (certificate number 1761676 ) with in excess of 4,000 hours as Pilot in Command

. I have added a hobby grade quad

- copter UAS ( Phantom 3 Professional ) to my inventory equipped with an attached camera with intent to perform aerial videography/cinematography and inspection to augment real estate listings, land development, events, promotional videos and aerial surveys following exemption and approval by the FAA. My, George W. Inskeep ’s, exemption request would permit operation of ultra

- lightweight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly con trolled and limited airspace, in areas away from the general public, airports, heliports and vehicular traffic . Such commercial operations will take place within property boundaries for individual homeowner real estate listing videos/photos , and such additional inspection, promotional and surveying operations as may be commercially viable . Currently, unmonitored amateur hobbyists with no safety plan o r controls in place to prevent catastrophe legally operate similar lightweight, remote controlled UAS’s in the National Airspace System. I, George W. Inskeep , have personally developed and implemented safety protocols and controls to avoid and prevent p ublic hazard . As a former commercial airline pilot, Naval Aviator and current licensed real estate broker I will apply thi s experience and my extensive background in aircraft operation and maintenance to the proposed project

. I expect to contribute materially to the body of knowledge of this fledgling industry and to assist the FAA in developing safety protocols exclusive to lightweight UAS operations as I, George W. Inskeep , record flight data and other information gained thro ugh permitted flight op erations.2

George W. Inskeep Sonoma, CA

– Section 333 Exemption Petition Granting my, George W. Inskeep ’ s, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the National Airspace System , but to “...establish requirements for the safe operation of such aircraft systems [UAS's] under Section 333(c) of the Reform Act specific to the use of UAS's for real estate, photography and videography purposes. ” Further I, George W. Inskeep , will conduct my operations in compliance with t he protocols described herein or as otherwise established by the FAA. For the reasons stated below I, George W. Inskeep , respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS’s to enhance real esta te listing videos for homeowners who cannot afford expensive manned aircraft, and to perform such other commercial photography and promotional services as may become available . This will promote local economic growth through increased employment and an inc reased tax base. It will further enhance public safety by replacing heavier manned aircraft containing combustible fuel that poses a potential public hazard. California has been plagued with serious drought conditions that only emphasize more the importan ce of using a UAS system as opposed to a fixed wing or rotorcraft in this area. If a mishap were to occur, flying either a rotorcraft or fixed wing airc raft carrying combustible fuels, the devastation to the surrounding area residents and economies could be disastrous. I. Contact Information: George W. Inskeep, 19170 Mesquite Ct. Sonoma, CA 95476 Office 415

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- 2716 Email: george@tridentboats.com II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which George W. Inskeep Requests Exemption are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). III. The Extent of relief George W. Inskeep seeks and the Reason He Seeks Such Re lief: I, George W. Inskeep , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent me, George W. Inskeep, from operating contemplated commercial cinematic, academic and other flight operations within the National Airspace System. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our National Airspace System as it is in the public’s interest to do so. My, George W. Inskeep ’s, ultra

- lightweight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore th e integration of my ultra light

-weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra

- lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft.3

George W. Inskeep Sonoma, CA

– Section 333 Exemption Petition Such approval will provid e direct experience and valuable information for formal regulation that can be administered unifor mly to all real estate and other commercial related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our National Airspace System. Considerations include: The weight, size, speed and overall capabilities of the UAS's , whether the UAS will be operated near airports or heavily populated areas, and whether the UAS will be operated by line of sight. Each of these items reflects in favor of an exemption for me, George W. Inskeep

. My UAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. It w eigh s less than five (5) pounds (far below the maximum 55

- pound limit) , including camera with gim bal. I, George W. Inskeep , consider safety as paramount with each flight. My small unmanned aircraft is designed to hover in place via GPS an d operate in a 13 Kn ot (15 mph) wind. For safety, stability and fear of financial loss my policy will be to n ot f ly in winds exceeding 8 Kn ots (10 mph). Built

- in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the Smart Mode for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost UAS is designed to slowly descend to point of take

- off. I do not and will not operate my UAS near airports, h ospitals, p olice heliports, or areas whe re the general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. I will be constantly on alert for any manned aircraft and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS is capable of vertical and horizontal operations, and is flown only within my line of sight (LOS) as the remote control pilot. Utilizing battery po wer rather than combustible fuels, flights generally last between five ( 5 ) to ten ( 10 ) minutes, with an altitude under two hundred ( 20 0) feet. I, George W. Inskeep , will utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is up to twenty

-five (25) minutes. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation , preferring to remain well within a safe operating range to insure adequate communication be tween radio control and UAS to eliminate potential for crash, loss of control or other hazard. Reserve batteries are at hand with each exercise to insure replacement for a sufficient ly safe level of operation. I do not believe in taking risk s that may ca use a crash, which could not only create a hazard to public/property/manned aircraft, but would seriously jeopardize the economics of the venture

. I have logg ed numerous practice flights in remote areas as a hobbyist simulating flights for future commerci al use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. I, George W. Inskeep , am extremely cautious when operating my UAS/ultra lightweight unmanned aircraft and will not “create a hazard to users of the National Airspace System or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the correspondin g directive to integrate UAS's into the National Airspace System. George W. Inskeep’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.4

George W. Inskeep Sonoma, CA

– Section 333 Exemption Petition IV. How George W. Inskeep’s Request Will Benefit the Public a s a Whole: Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed

-wing aircraft and helicopters. For small budget real estate companies and average homeowners, the expense of such aerial videography is cost prohibitive. Only large companies and wealthy brokers or luxury homeowners can afford to absorb such expense, d epriving non

- luxury homeowners and lower budget brokers from a valuable marketing too l. My, George W. Inskeep’s, UAS offers an effective and low cost alternative while pos ing a much lower environmental th reat since size and lack of combustible fuel minimiz es any potential threat to the public. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the National Airspace System, hence the passing of the Reform Act. Granting my, George W. Inskeep’s, exemption request furthers the public interest through academic/visual awareness of th e geographical benefits in and around Sonoma County, California . My ultra lightweight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra lightweight UAS crashing is far less than a full size helicopte r or fixed wing aircraft, which are heavy, contain combustible fuel and can cause catastrophic devastation to the public. Again, considering the extreme fire danger present now in all o f California due to our current drought conditions, any actions to pos sibly mi nimize the operation of aircraft carrying combustible fuels for aerial photography or surveying and potentially having a mishap is both significant and in the best interest of the publ ic. The public’s interest is furthered by minimizing potential ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra lightweight UAS's. Permitting me, George W. Inskeep , to immediately fly within national air space furthers economic growth. Granting my exemption reque st positively impacts the economic s of the County of Sonoma, from real estate sales, inexpensive aerial surveying and aerial support of the thriving viticulture industry which is a major employer and economic engine for Sonoma and the surrounding counties. All of these factors provide a potential economic stimulus to the community.
V. Reasons Why George W. Inskeep ’s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: My, Georg e W. Inskeep ’s, exemption will not adversely affect safety. Quite the contrary, for the reasons previously stated permitting me, George W. Inskeep , to log more flight time in FAA controlled airspace, with ongoing communication with the FAA, will allow me to contribute to the continued development and implementation of new and novel, as yet undiscovered safety protocols for the UAS community, promoting growth and safety of this new and vital industry in cooperation with the FAA. In5

George W. Inskeep Sonoma, CA

– Section 333 Exemption Petition addition I, George W. Ins keep , submit the following representations of enhancements to current aerial videography and photography for real estate and other opportunities, to illustrate its benefits : My UAS weighs less than 5 pounds complete with a small ultra lightweight high qu ality built

- in camera; I only operate my UAS at or below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only operate s for a maximum of 37 minutes per flight; I will land my UAS prior to m anufacturer recommended minimum level of battery power; I pilot my UAS through remote control only by visual line of sight (VLOS); My UAS has GPS flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot i s lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; I only operate in a safe environment that is strictly controlled, away from power lines, elevated lights, airports and actively popu lated areas; I conduct extensive pre

-flight inspections and protocol during which safety carries primary importance; I always obtain all necessary permissions prior to operation , and I have procedures in place to abort flights in the event of safety breach es or potential danger. I am also very familiar with pre

-flight procedures for both certificated and experimental civil aircraft

. I am intimately familiar with the rules and limitations for the safe operation of all types of aircraft. My, George W. Inske ep ’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our planned environment that helicopters are the primary means of aerial video and photography for community awareness, aerial surveying and real estate. First, the potential loss of life is diminished because UAS's carry no people on board and I only operate my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosion is essentially eliminat ed. Third, the small size and extreme maneuverability of my UAS allows me to remotely pilot away from and avoid hazards quickly and safely. Lastly, the photographic sophistication o f the equipment carried on my UAS permits operation from a safe distance. Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels. I will also be carrying a port able aviation radio to notify any aircraft operating in the vicinity of nearby UAS operations. VI. A Summary t he FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Su bpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, George W. Inskeep ’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (4 9 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit6

George W. Inskeep Sonoma, CA

– Section 333 Exemption Petition the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as ai rports and dense populations. My, George W. Inskeep ’s, current and projected UAS's meet or exceed each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be appli cable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is i napplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas wherein safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299 A, 9565, 9565B, 10167, 10167A, 10602, 10700, 32827 and many others. 14 C.F.R. § 91.121 regarding altimeter settings are inapplicable in so far as my UAS utilizes electronic global positioning systems with a barometric sensor. 14 C.F.R. § 91.203 (a) a nd (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registratio ns by me, George W. Inskeep B. 14 C.F.R. § 45.23: Marking of t he Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark the UASs in the largest possib le lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I, George W. Inskeep , being a l icensed Commercial Pilot, do not come under this section, but nonetheless achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ens ure remote control piloting skills. The risks attended to the operation of my UAS are far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, George W. Inskeep, to operate my UAS meet s and exceed s current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitud es in certain conditions. My UAS will never operate at an altitude greater than 200 AGL, safely below the standard of 400 AGL.7

George W. Inskeep Sonoma, CA

– Section 333 Exemption Petition I, George W. Inskeep , will however operate my UAS in safe areas away from public and traffic, providing a level of altitude sa fety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 41 7(a) & (b): Maintenance Inspections. The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as prov ided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter . . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, George W. Inskeep ’s, U AS. However, as a safety precaution I inspect my UAS before and after each flight. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and encl osed operational area of my UAS permits exemption from Part 21 because my, George W. Inskeep’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability a nd proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent l evel of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curativ e measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved. In summary, George W. Inskeep , seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b) ; 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, George W. Inskeep’s, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, real estate operations and other opportunities whi ch may present itself. Currently, area8

George W. Inskeep Sonoma, CA

– Section 333 Exemption Petition awareness and real estate aerial videography/photography relies primarily on the use of larger aircraf t running on combustible fuel, p osing potential risk to the public. Granting my, George W. Inskeep ’s, request fo r exemption will reduce current risk levels and thereby enhance safety. My UAS aircraft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flig ht time. Further, I operate at lower altitudes and in most cases away from controlled airspace eliminating potential public risk flying to and from established airfields. I, George W. Inskeep , have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for real estate and other commercial usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance t he FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, George W. Inskeep ’s, UAS and therefore the likelihood of death or serious bodily injury is significantl y diminished. My, George W. Inskeep ’s, operation of my UAS, weighing less than 5 pounds and travelling at low speeds within limited areas will provide an equivalent level of safety as that achieved under c urrent FARs. Accordingly I, George W. Inskeep , re spectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large. Respectfully submitted,

George W. Inskeep, 19170 Mes q uite Ct. Sonoma, CA 95476 P.O. Box 393 Sonoma, CA 95476 415

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Attached: Preflight Form and Checklist