September 30, 2015

U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Ave, SE Washington, DC 20590

PETITION FOR EXEMPTION UNDER SECTION 333

The following elements are presented per CFR 14 SS 11.81:

**PETITIONER**
William K. Fowler, Jr. (FAA ATP 2665037) 4735 Howe Pensacola, FL 32504-9034

DBA: To be determined
UAS: Aircraft to be used will be professional-grade models with known history of safe flight. Makes/models will include, but not limited to: TurboAce Matrix and DJI Phantom.

**SPECIFIC EXEMPTIONS AND INTENT TO SEEK** WILLIAM K. FOWLER, JR, hereafter referred to as ‘PETITIONER’ seeks exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate Unmanned Aerial Systems (UAS) for commercial purposes pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) (PUBLIC LAW 112-95)

.**SCOPE** This exemption will permit the PETITIONER to operate an Unmanned Aircraft System (UAS) for commercial purposes in the National Airspace Sytem (NAS) ofthe United States for, but not limited to, the following endeavors; still and videographic content for real estate, marketing, media outlets , law enforcement/ government, event production/production, historical needs, and flight training individuals and institutions in UAS/NAS operations.

**EQUIVALENT SAFETY & PUBLIC BENEFIT** PETITIONER has operated with zero mishaps during entire flying experience beginning in 1987. PETITIONER has approximately 8,000 hours of airline transport flight in, and a comprehensive knowledge of, operations and safety in the NAS. PETITIONER has in excess of 2 years experience in UAS operations and planning to include over 100 hours of UAS flight training. PETITIONER ’s history of safety, and dedication thereto, will ensure equivalent safety and public benefit.
PETITIONER will ensure ‘equivalent safety’ and ‘public benefit’ via, but not limited to the following practices and protocols for UAS operated under this exemption :

- situational awareness - ‘pre’ and ‘post’ flight inspections - manufacturer recommended maintenance - pre-flight planning; WX, TFRs, file NOTAMs, etc. - coordination with local law enforcement to mitigate public alarm - compliance with 14 CFR and Federal Aviation Regulations (FARs)
PETITIONER, William K. Fowler, Jr., pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b).PETITIONER shall comply with speed, weight, size, and operating area limitations set forth in FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Accordingly, PETITIONER requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.
Despite holding an FAA Medical Certificate and ATPL with three type-ratings in the course of his employ as a pilot executing air carrier operations with a large FAR 121 carrier, PETITIONER also seeks relief from Section 61.113(a) and (b), entitled Private pilot privileges and limitations: pilot in command.
PETITIONER also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the UAS has no barometric altimeter onboard. Flight information (including altitude) are provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude information, combined with the PETITIONER’s operation of the UAS within visual line of sight, at or below 200 feet AGL, at a speed no greater than 80 knots will ensure a level of safety equivalent to Section 91.121.
Additionally, PETITIONER seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. With average flight requirements of 15 minutes, safety will not be affected by operation of UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 20 minutes. Flights will be aborted safely if battery charge reaches an unsafe level.

**SUMMARY (for Federal Registry)** In accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, PETITIONER respectfully requests that the Administrator grant this petition for ‘Exemption from the requirements of 14 C.F.R Sections 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)’ and permit William K. Fowler, Jr. to operate UAS commercially for the purpose of, but not limited to, conducting aerial videography/ marketing in the NAS of the United States.Due to the incongruent relationship of UAS and certain sections of 14 CFR intended for traditional aircraft, PETITIONER respectfully request exemption from any, and all, sections that do not apply to the UAS to be used.
Examples of incongruity not applicable to many UAS: -traditional airframe vs. single piece composite hull -traditional power plant vs. electric motors -traditional fuel vs. electric power -weight & balance vs. fixed CG (within 18-36 inches)

**ADDENDUM** PETITIONER has operated with zero mishaps or violations during entire flying experience beginning in 1987. PETITIONER has approximately 8,000 hours of airline transport flight in, and a comprehensive knowledge of, operations and safety in the NAS. PETITIONER is confident past performance and habits will translate into safe UAS/NAS operations. Further, petitioner will place a priority on outreach in attempt to educate fellow UAS operators, and the public, on the importance of safe UAS integration into the National Airspace System.

**FOREIGN OPERATIONS** None sought.

Respectfully Submitted,

///W. FOWLER///
William K. Fowler, Jr. FAA ATPL 2665037

[Originally submitted on 09/30/15]