U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12B140 1200 NewJerseyAvenue, S.E. Washington, DC 20590 

### Petition for Exemption Under 14 CFR § 

### 11.81. to Allow Commercial Use ofUnmanned Aircraft Systems

Petitioner:
Michael Robbins 4450 El Centro Road #416 Sacramento, CA 95834
310-866-0318 mostey@gmail.com

To Whom ItMay Concern, 

### Prepared By:
Sam Estrin Drone Universities 10444 Cheviot Court San Diego, CA 92126
310-613-0562 sam.estrin@droneuniversities.com http:/ fdroneuniversities.com

This application is substantiallybased on the FAA's findings in Exemption No. 11351 granted to Corp on April17, 2015, and in reliance on the analysis provided therein.
1. Sections from which exemptions are sought: Application is hereby made for exemption from: a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333 b

. 14 CFR Part 21, subpartH c. 14 CFR Part 61.113(a) and (b) d. 14 CFT Part 91 i. 91.103(b)(2) ii. 91.105 iii. 91.109 iv. 91.119 v. 91. 121 vi. 91.151 vii. 91.405 viii. 91.407

ix. 91.409
©Copyr ig

ht 2015, Drone Universities, All Right s Reserved. Revision 1 July 9 t h, 2015X. 91.417 2. Reliefsought: a. Michael Robbins wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but notbe limited to) videography, cinematography, photogrammetry, industrial inspections and analyses. This reliefis soughtbecause law currently prohibits commercial use of sUAS unless performed under an exemption. b. This exemption will cover use ofthe following airframes, all ofwhich will weigh less than 55 pounds including payload and energy sources: i. DJI Phantom FC40 ii. D JI Phantom 2 iii. D JI Phantom 3 iv. Other models to be added by future amendment to this exemption. 3. Public benefit: a. Use ofsUAS technology to obtain imagery, information and data currently obtained by use ofmanned flight or manual methods: i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., powerline inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging failures during stack orbridge inspections). ii. Reduces the cost ofobtaining such information, which benefits
consumers and the economy. iii. Reduces environmental impactby eliminating sources of hydrocarbon emissions from manned aircraft. 4. Safety not adversely affected:
a. Aircraft will be registered and marked in accordance with Section 44711 and Part47 and Part 45, SubpartC. b. Aircraft will complywith maintenance and inspection requirements of the manufacturer. All repair and maintenance work will be conducted or approved by qualified personnel such as those authorized by Robotic Skies (or equivalent), and will require a test flight after such work. Records ofall maintenance and repair work will be kept in a maintenance log for each aircraft. c. All flight operations will be conducted by at least two individuals (PIC and observer) who will maintain verbal communication capability with each other at all times during the flight, and who will remain stationary on the ground during the flight operations: i. A Pilot In Command (PIC) who possess the following credentials: 1. An Airman Certificate issued under 14 CFR 61 (private 

### pilot license) screened by

### the TSA 2. A Third Class m edical certificate issued under 14 CFR 67 ©Copyr ight 2015, Drone Universities, All Rights Reserved. Revision 1 July 9 t h, 20153. A bi-annual flight reviewunder 14 CFR 61.56 4. A certificate ofcompetency for UAS issued byDrone Universities, UMEX or equivalent certification 5. At least 200 cycles and 25 hours offlight experience in a UAS rotorcraft (or UAS fixed-wing in the case offixedwing flight operations under this exemption). Such cycles and hours maybe gained during flights under this exemption ifa safe distance is maintained from persons in accordance with 14 CFR 91.119 6. At least 5 hours offlight experience and 3 takeoffs and landings in make and model being flown inthe prior 90 days. Such cycles and hours maybe gained during flights under this exemption ifa safe distance is maintained from persons in accordance with 14 CFR 91.119 ii. AVisual Observer m. A Sensor Operator (whenever necessary) d. All flight operations will be conducted in accordance with valid Certificates ofAuthorization e. All flight operations will complywith the following: i. The manufacturers' Aircraft Flight Manuals and Operation Guidelines ii. Michael Robbins flight operations policies including lost communication and other emergency and safety procedures. iii. Conducted inVMC conditions during daylight hours. iv. PIC and VO will maintain VLOS at all times. v. Pre-flight inspections (including ground control station, ifany) and safety risk assessments will be conducted priorto each flight. vi. Flight altitudes will remain below400 feet above ground level. vii. Flight ground speeds will not exceed 50 knots. viii. Not intrude into Class B, CorD airspace, orpublished approach, SID or STAR, ortake place within 5 nautical miles ofan airport ix. Not be made nearpersons as required in 14 CFR 91.119 and not over persons on the ground withouttheirpriorpermission. x. Each flight will be logged in both the PIC's logbook and the aircraft logbook xi. Not exceed 75% ofthe battery or fuel capacity ofthe aircraft, or 30 minutes, whichever occurs first. xii. Any incidents will be reported to NTSB within 24 hours of occurrence. xiii. Michael Robbins will maintain liability insurance ofatleast $1,000,000 issued by a major aviation insurance underwriter. xiv. Any applicable local FSDO requirements.
©Copyright 2015, Drone Universities, All Rights Reserved

. Revision 1 July 9 t h, 2015xv. All other applicable regulations concerned with the operation ofaircraft. f. Aircraft will use 2.4 GHz for control ofthe aircraft, and 5.8 GHz for sending data with well-defined and tested lost link procedures.
Please advise us ofany additional information or changes that may be required.

Sincerely,

Michael Robbins 

### 07/09/2015

©Copyright 2015, Drone Universities, All Rights Reserved. Revision 1 July 9th, 2015