Collins B. Case

9980 Rail Circle Pensacola, FL 32507 601 757 0873 Cbc0873@gmail.com

Dear Sir or Madam:

This petition is being submitted on my behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Collins B. Case, a freelance aerial photographer and videographer, applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow for the operation of a Small Unmanned Aircraft S ys tem (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by

the FAA as required by

Section 333. The requested exemption would permit Collins B. Case to pursue his commercial interests in providing services using a small advanced sUAV in the following areas: Education, Land Development and Erosion

, C onstruction, Farming, Real Estate, Marketing

, Management/Surveying, Private and Public Events , Business Promotion, and related Economic Developme nt

. Collins B. Case has demonstrated the ability to safel y and effectivel y fl y the sUAS DJIPhantom 3 Standard which will be used for all commercial and private purposes. Collins B. Case complies with local ordinances and laws regarding the operation of sUAS and adheres to all weather and environmental restrictions or limitations in reference to the operations of s UAS. As a certified Federal Aviation Safety Officer, Collins B. Case possesses and utilizes skills
necessary for the safe operations of aircraft such as decision making, assertiveness, mission anal ys is, communication, leadership, adaptability /flexibility

, and situational awareness. Additionally , Collins B. Case has exemplified the highest standards of aviation safety while serving in the military

as a Naval Flight Officer since 2008.

All flights will occur in compliance with an y state or local ordinances or laws regarding privacy

. I, Collins B. Case, am seeking the exemption because I am committed to complying with all of the rules, guidelines, limitations, and future legislation set forth by the FAA. Iagree to operate the sUAS in the manner that Ihave described, and for the purposes that I have described. Without the exemptions request granted, I would be unable to safel y and effectivel y explore the listed sUAS commercial opportunities, and it is my intention to comply with the FAA and obtain an exemption of the regulations listed below.

The following contains a list of regulations from which Iam seeking ex emption, and an extensive list of responsibilities Iassume as operator; it also contains information regarding the aircraft, public bene fit and safet y features, and similar petitions requests granted. **Regulations from which exemption is requested:** 14 C.F.R. Part 21 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. 91.109

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) & (b) 14 C.F.R. 91.205(b) 14 C.F.R. 91.215 14 C.F.R. 91.401

– 91.417

**I, THE OPERATOR, ASSUME THE FOLLOWING CONDITIONS, LIMITATIONS,**  **AND RESPONSIBILITIES**  1. Operations authorized by this grant of exemption are limited to the DJ I Phantom 3 Standard when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of closed

- set motion p icture and television filming are not permitted. 3. The UA may

not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may

use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restric tion. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be rep orted in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman m edical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be op erated within the VLOS of the PI C and VO at all times. The VO may be used to satisfy

the VLOS requirement as long as the PI C alway s maintai ns VLOS capability . The VO and PI C must be able to communicate verball y at all times; electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outli ned in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator ma y update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. I f the operator determines that an y update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendme nt to its grant of exemption. TheFAA’s UAS Integration Office (AFS −80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted b y a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and propert y. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a

con dition for safe operation. 10. Prior to each flight, the PI C must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 1 1. The operator must follow the UAS manufacturer’ s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safet y bul letins. 13. Under this grant of exemption, a PI C must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PI C must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued b y a state, the District of Columbia, Puerto Rico, a territory , a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate. 14. The operator may

not permit any

PIC to operate unless the PI C demonstrates the abilit y to safel y operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintainin g appropriate distances from persons, vessels, vehicles, and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, p roficiency , and experience

- building) and determining the PI C’s ability

to safel y operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may

not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight ru les (SVFR) are not authorized. 16. The UA may

not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airports not denoted with an ARP, the center of the airport sy mbol a s denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by

a COA issued to the exemption holder. The letter of agreement with the airportmanagement must be m ade available to the Administrator or an y law enforcement official upon

request. 17. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PI C. 18. For tethered UAS operations, the tether line must have colored pennants or streamers attached at not more than 50 foot intervals beginning at 150 feet above the surface of the earth and visible from at least one mile. This requirement for pennants or streamer s is not applicable when operating exclusively below the top of and within 250 feet of any structure, so long as the UA operation does not obscure the lighting of the structure. 19. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property

. 20. The PI C must abort the flight in the event of unpredicted obstacles or emergencies. 21. The PI C is prohibited from beginning a flight unless (considering wind and for ecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater. 22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder
may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the enclosed COA. 23. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markin gs must be as large as practicable. 24. Documents used b y the operator to ensure the safe operation and flight of the UAS and an y documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS an y t ime the aircraft is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 25. The UA must remain clear and give way to all manned aviation operations and activities at all times. 26. The UAS ma y not be operated b y the PIC from any moving device or vehicle. 27. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficient ly protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of an y vessels, vehicles, or structures has granted permission for operating closer to those obj ects and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PI C, VO, operator trainees or essential persons are not considered nonparticipating persons under th is exemption. 28. All operations shall be conducted over private or controlled

- access property with permission from the property

owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be o btained for each flight to be conducted.29. Any

incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Safet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

**SIMILAR EXEMPTIONS** They are similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213, **14 CFR 21 H: Airworthiness Certificates** Certification Procedures for Products and Parts **Reason for Exception** It has been determined that similar UAS's do not require an airworthiness cert ificate as granted in Exemption No. 11623, 11650, 11664, 12701 and 11734. **14 CFR 45.23 (b): Marking of the Aircraft** These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Addi tionally , the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. **Reason for Exception** Even though the UAS will have no airworthiness certificate, an exemption may be ne eded as the UAS will have not entrance to the cabin, cockpit or pilot station on which the work "EXPERIMENTAL" can be placed. Given the size of the UAS, two

- inch lettering will be impossible. The word "EXPERIMENTAL" will be placed on the fuselage in compli ance with 45.29 (f). The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. **14 CFR 61.113 (A) 7 {b): Private Pilot Privileges and Limitations** The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person: (1) has a pilot certificate or special purpose authorization issued under this part in that person's phy sical possession or readily accessible. (2) The flight is onl y incidental to that business or employment. (3) The aircraft does not carry passengers or property

for compensation or hire. **Reason for Exception** The Petitioner will follow all manufacturers' current training programs and safety manuals. Current FAA p roposals have omitted this as a requirement for sUAS. T hese requirements are
unnecessary

for small

- sized ground station pilot controlled sUAS flights. PIC will ensure every aspect of this petition is followed, maintained, and documented in depth across al l sUAS operations if granted exemption.

**Public Benefit and Safety** Each ye ar man y people throughout the country waste critical time and resources on inaccurate construction, building repair, farming, and land development estimates and bids. The intention of this exemption is to gather w ell documented imagery and photographic analy

tical data of buildings and land in order to more efficientl y provide services made possible by sUAS technology

which require s less risk of injury or death on behalf of constructi on and land
survey ors and associate purveyors therein. As a certified Federal Aviation Safety Officer, CollinsB. Case understands the vital importance of safety as it applies to the aviation environment. Collins B. Case is petitioning for an exemption to operate a DJ I Phantom 3 Standard with GPS safet y f eatures which limit the height it flies above ground level (AGL), the radius of the distance it flies from the operator

, and to exclude it from operations within designat ed Class B, C and D airspace i ncluding a no

- fl y zone feature. The DJ I Phantom 3 Standard also has a failsafe function that is triggered in the event co mmunication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will ret urn to its point of takeoff and land safel y. If the connection is restored, the PI C can regain contr ol of flight and land manually

. These specifications meet with the Model Aircraft Operating Standards as set below:

 The petitioner will only operate its sUA S in line

- of

- sight of a pilot and/or observer and will operate at sites that are `sufficient distance' from populated areas within the sterile area described in the FO PM. Such operations will ensure that the sUAS will "not create a hazard to users of the n ational airspace sy stem or the public."

 When flying the sUAS within three (3) miles of an airport, airport operators will be notified and the operator will give the right

- of

- way to avoid fl yi ng in the proximity of full

- scale aircraft. Maximum flight time f or each operation will be 25 minutes.

 Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safel y l and the sUAS.

 The sUAS will be programmed so it will not be operated at an altitude that exc eeds 400 feet AGL , and not more than 200 feet above an elevated platform from which videograph y is planned.

 Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer, and the camera operator.

 The sUAS operated b y the petitioner weighs less than 3 pounds, including all payloads (i.e. camera, lens, and stabilized gimbal).

 The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously

move vertically

and horizontally

.

 Given the small size of the sUAS and the restricted st erile environment, within which it will operate, the stated operations adhere to the Reform Act's safet y requirements.

Sincerel y,

Collins B. Case