U.S. Department of Transportation

Docket Management Sy stem 1200 New Jersey

Avenue SE Washington, DC 20590 Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the FAA Regulations and certain parts of the FARs. Dear Sir or Madam: **Request:** In order to provide safe an d environmentally

- friendly aerial videography

and photograph y for and public business interests, I, Jon Fish , pursuant to Section 333 of the FAA Modernization and Reform Act of2012 ("FRMA"), would like to formally submit for exemptions from the following Section 333 regulations:
14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b)(2) 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(l), 14 C.P.R. 91.203(a) and (b), 14 C.F:R. 91.405(a), 14 C.F.R. 91.407(a)(l), 14 C.F.R. 91.409(a)(l) and (2), 14 C.P.R. 91.417(a) and (b)
I am requesting these exemptions so that Imay safely operate the Parrot AR Drone 2.0 professional UAS commerciall y alon g the guidelines of the accompan yi ng operator's manual as well as P

AA guidelines for UAS flight and safety guidelines set by the Academ y of Model Aeronautics (AMA). **Proposed** UAS **and Operations** The Parrot AR Drone 2.0 weighs less than three pounds, will alway s be flown under 400 feet limited via software by its GPS and barometric sensors, is electricall y powered b y a lithium ion battery , carries no combustible fuel or crew, and will be transported in proper storage to and from all flight areas (in accordance with FAA November 17,2015 guidelines). The aforementioned proposed exemptions would allow me to operate the Parrot AR Drone 2.0 UAS for commercial purposes of aerial videography and photograph y as a service to publi c and business interests, including: real

- estate photograph y and videography, wedding and private individual photograph y andvideograph y, public and commercial photograph y and videograph y, and agricultural

photograph y and videography. Being a business owne r in Professional Media and Media Management and a professor at Chattanooga State Community College in Tennessee , I would also use this UAS to produce projects for my classes duties, the products of which may be published in local area businesses and on th eir respective websites. As evidenced b y recent Exemption Nos. 12045 and 12058, the FAA recently approved similar use of the Parrot AR Drone 2.0 UAS. These particular UAS have been proven reliable and safe flying machines managed by gy roscopically

- stabil ized flight, ground detection, GPS

- aided navigation, a built

- in compass, blinking LED lights, a manual and automatic failsafe "Return To Home" mode for returning to the point of takeoff, and propeller guards in order to protect both the UAS and the environment. This particular model combines state

- of

- the

- art, proven technology with high quality

manufacturing and user - friendly

control to ensure safe operation and eas y maintenance and care. **Specific section(s) of 14 CFR which I seek relief and the reason(s) I seek relief:**  14 C.F.R. Part 21: Airworthiness Certificates Given the size and limited operating area associated with the UAS to be utilized, an exemption from Part 21 meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. As evidenced in Exemption No. 12045, "in all cases, an anal ys is of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at lea st as safe, or safer, than conventional aircraft operating with an airworthiness certificate without restrictions and conditions proposed." 14 C.F.R. 45.23: Display o f marks: general Because the Parrot AR Drone 2.0 does not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark large words, numbers, or phrases, I request exemption from the above regulation. However, in efforts to comply with the above regulation and those set by

the Academy

of Model Aeronautics (AMA), I will affi x a small label to the external hull of the UAS indicating m y name and address , and m y AMA Member Number.
14 C.F.R. 61.113(a) & (b

): Private pilot privileges and limitations: Pilot in command Under § 61.113 (a) and (b), certified private pilots are limited to noncommercial operations. However, I am able to achieve an equivalent level of safet y through current FAA regulations of UAS operation and AMA safety guidelines (outlined in the summary of this document) without such a certification because of the above mentioned safety features of the Parrot AR Drone 2.0

. According to Exemption No. 12045 in which Parrot AR Drone 2.0 was authorized for similar operation, "The FAA has previously declared that additional manned airship experience of a commercially certified pilot would notcorrelate to the airmanship skills necessary for similarly

proposed operations in previously

issued exemptions to this regulation through Exemption Nos. 11062 and 11138." Therefore, bearing an y pilot certification or license will not ensure remote piloting skills o f a UAS; the risks o f operating this UAS are far less than the risk levels inherent in commercial activities with traditional aircraft given the Parrot AR Drone 2.0 safet y features and the limited range and speed of the UAS. The FAA has approved a similar exemption to the above rule as evidenced in Exemption No. 12058. 14 C.F.R 91.7: Civil aircraft airworthiness Currently there is no certificate applicable to this UAS, and therefore it will be up to my self, Jon Fish , to determine the airworthiness of the Parrot AR Drone 2.0 in accordance with its official operating manual. Written and signed pre and post

- flight in spections of the propellers, motors, frame, landing stands, camera and gimbal unit, connected tablet devices, a compass calibration and properl y ensured GPS locks as indicated b y the Parrot AR Drone 2.0 display of "Saf e to Fl y" message will be perfor med be fore and after each flight, accurate records of which will be kept with the UAS's storage and transportation sy stem at all times. These records will be dated and will include the total flight time of each flight. 14 C.F.R. 91.9 (b)(2): Civil aircraft fli ght manual, marking, and placard requirements As evidenced in Exemption 12045, since there are "no pilots or passengers on board this aircraft, and given its size, this regulation is inapplicable. A n equivalent level o f safety will be achieved b y m ainta ining a safety/ flight manual with the operator." In addition to the official safety/ flight manual provided b y Parrot upon purchase of the Parrot AR Drone 2.0 , following the AMA guidelines for safe flight operations and the FAA regulations for UAS operation s will ensure a high level of safety

. 14 C.F.R. 91.119(c): Minimum safe altitudes I, Jon Fish will ensure that the UAS does not operate an y higher than 400 feet at ground level by setting the maximum altitude at 400 feet in Parrot AR Drone 2.0 pilot ap plication and ensuring this is set before each flight as part of the pre

- flight inspection. Iwill not fly over congested areas or directly above unprotected people or moving vehicles. I will plan operations before hand for proper flight safety and proper height anal ys is as to avoid collisions. The GPS and barometric sensors equipped on the Parrot AR Drone 2.0 will ensure accurate altitude readings, the output of which will be fed to my tablet device in real time as I operate the UAS. 14 C.F.R. 91.121: Altimeter settings The Parrot AR Drone 2.0 utilizes the latest GPS/GLONASS technologies as well as a barometric sensor with live data output to the tablet device attached to the transmitter. An equivalent level of safety and accurate al timeter telemetry will be achieved by

using this.14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The Parrot AR Drone 2.0 is electricall y - powered by lithium ion batteries which are made by Parrot specifically

for this particular UAS. They are rated as providing no longer than 25 minutes off light time. Therefore, due to the limitations of the batteries, it is currentl y impossible to comply

with part 91.151. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required
Currently , there are no procedures for providing airworthiness certificates for the mentioned UAS. I, Jon Fish , however will alway s fly safel y while having the manuals of the Parrot AR Drone 2.0 and abiding b y FAA regulations for UAS operation and AMA safet y guidelines. 14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(l): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(l) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections may be required and should be granted since they apply to aircraft with an airworthiness certificate. However I , Jon Fish , will perform both preflight and post

- flight inspections of the UAS before and after each flight as outli ned in the operating documents. I, Jon Fish , will also follow manufacturer recommendations from said operating documents and keep a written record of an y maintenance done to the UAS. **Public Interest and Public Safety:** Aerial photograph y and videograph y provided to the public allows for a more cost

effective, safe, and environmentally

- friendl y method to capturing imagery than its alternative: manned aircraft and helicopters. The latter are expensive to operate and maintain, create a high level of noise, and are much more hazardous due to size and combustible fuel

- especially if flown at low altitudes required for some operations. I, Jon Fish , in addition to using my UAS for commercial endeavors, will also gladly offer m y services free of charge upon requ est and with proper coordination to any official search and rescue or emergency

services organization to benefit the public. Because of this, an increase of commercial activity and a gaining of more detailed understanding of private and/or farm land would help local and area communities by : reducing pollution, risk, and operating costs b y alternative aerial video and photograph y s ervices such as manned airplanes and helicopters, reducing carbon emissions and traffic congestion by vehicles looking to view p roperties such as real

- estate or farm land, and increase visibility to local attractions thereb y bolstering local commerce and tourism. Given that there is no fuel and no crew on this UAS, that it weighs under three pounds and has propeller guards, as we ll as having a low maximum speed (less than 25mph), safe operation of this craft does not pose any immediate danger to the environment, wildlife, infrastructure or people. Parrot AR Drone 2.0 has built in a "No Fl y Zone" for major cities and points of int erest that have registered as a "do not fl y zone." Operation of the Parrot AR Drone 2.0 cannot happen in these locations, as an y flight capabilities becomesblocked b y the UAS itself if within range and the operator is notified. Given its GPS and

ground

- se nsing capabilities, a failsafe "Return To Home" mode will safel y return the craft to the operator at the push of a single button or automaticall y when the craft is either low on power or operating outside of its transmitter's range. This ensures that the c raft will not remain airborne in unsafe conditions and pose any public danger. **Summary** I, Jon Fish , am seeking exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C. F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(l), 14 C.P.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)(l) and (2), 14 C.F.R. 91.417(a) and (b). With the exemptions of the mentioned rules I, Jon Fish , will be seeking to make m y UAS photograph y/videography services available to public and commercial interests. The FAA has authorized similar operations under Exemption Nos. 12045 and 12053. Alternatively , public and commercial interests had previously sought the use of manned aircraft to achieve what I can offer in a safer, more cost

- efficient and environmentally

- friendly manner b y not using combustible fuel, flying at safe heights and strictly following the usage recommendations from Parrot AR Drone 2.0 and safe ty procedures b y the Academy of Model Aeronautics. These include but are not limited to: • Flying the Parrot AR Drone 2.0 safel y in accordance with its operator's manual • Maintaining active and full membership in the Academ y of Model Aeronautics (AMA), which provides' a high level of insurance and training programs to it ’ s members. • Alway s fl yi ng below 400 feet, using the Parrot AR Drone 2.0 altitude limiter to ensure this. • Completing thorough inspection of UAS before and after flights and keeping i nspection records with the craft at all times • Keeping the UAS in visual sight at all times when in operation • Using an observer to assist if ne eded • Remaining safel y clear o f and do not interfere with manned aircraft operations • Not flying directly

ov er unprotected persons or moving vehicles • Not flying within 5 miles of an airport or control tower • Not flying in adverse weather conditions such as high winds, rain, or impaired visibility • Not flying under the influence of alcohol or drugs • Ensurin g the operating environment is safe • Not flying over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, etc. • Checking and following all local laws and ordinances before fl yi ng over private propert y • Not conducting surveillance or photographing persons in areas where there is an expectation o f privacy

without the individual's permission In addition to these above general standards, I, Jon Fish , will follow and abide by the following AMA safet y guidelines:A. [DEFINIT ION]: A "model aircraft" is a non

- human

- carrying aircraft capable of

sustained flight in the atmosphere. [This includes UAS such as the Parrot AR Drone 2.0 ].
1. Model aircraft w ill not be flown: (a) In a careless or reckless manner. (b) At a location where model aircraft activities are prohibited. 2. Model aircraft pilots will: (a) Yield the right of way to all human

- carrying aircraft. (b) See and avoid all aircraft and a spott er must be used when appropriate. (AMA Document #540

- D.) (c) Not fl y higher than approximately 400 feet above ground level or within five miles of an airport. (d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base. (e) Not exceed a takeoff weight, including fuel, of 55 pounds. (AMA Document 520

- A.) (f) Ensure the aircraft is identified with the name and address or AMA number of the owner on the inside or affixed to the outside of the model aircraft. (g) Not operate aircraft with metal

- blade propellers or with gaseous boosts (AMA Document #555.) (h) Not operate model aircraft while under the influence of alcohol or while using an y drug that could adversel y affect the pilot's ability to safel y control the model. (i) No t operate model aircraft carrying py rotechnic devices that explode or bum, or any device which propels a projectile or drops any object that creates a hazard to persons or propert y. G) Not operate a turbine

- powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document #510

- A.) 3. Model aircraft will not be flown in AMA sanctioned events, air shows or model demonstrations unless: (a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intend ed or anticipated prior to the specific event. (b) An inexperienced pilot is assisted by an experienced pilot.
4. When and where required b y rule, helmets must be properl y worn and fastened. They must be OSHA, DOT, ANSI , SNELL or NOCSAE approved or comp ly with comparable standards. B. RADIO CONTROL (RC)
1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.2. A successful radio equipment ground

- range check in accordance with manufacturer's

recommendations will be completed before the first flight of a new or repaired model aircraft. 3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Document #706.) (a) Onl y personnel associated with flying the model aircraft are allowed at or in front of the safety line. (b) At air shows or demonstrations, a straight safety line must be established. (c) An area away from the safety

line must be maintained for spectators. (d) Intentional fl yi ng behind the safety line is prohibited. 4. RC model aircraft must use the radio

- control frequencies currentl y allowed by the Federal Communications Commission (FCC).
5. RC model aircraft will not knowingl y operate within three (3) miles of any pre

- existing flying site without a frequency

- management agreement. (AMA Documents #922 an d #923.)
6. With the exception of events flown under official AMA Competition Regulations, excluding takeoff and landing, no powered model may be flown outdoors closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the flight line.
7. Under no circumstances may a pilot or other person touch an outdoor model aircraft in flight while it is still under power, except to divert it from striking an individual.
9. The pilot of an RC model aircraft shall: (a) Maintai n control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot. (c) Fly using the assistance o f autopilot or stabilization system onl y in accordance with the procedures outlined in AMA Document #560.
C. FREE FLIGHT 1. Must be at least 100 feet downwind of spectators and automobile parking when the model aircraft is launched.
2. L aunch area must be clear of all individuals except mechanics, officials, and other fliers.
3. An effective device will be used to extinguish any [fire] on the model aircraft. 4. The fl yi ng area must be clear of all utility wires or poles and a model aircraft will not be flown closer than 50 feet to an y above

- ground electric utility lines.5. Th e fl yi ng area must be clear of all nonessential participants and spectators before the

engine is started. I thank yo u for your time and effort in processing this request and look forward to cooperating with the FAA in its continued commitment for the saf e operation of UAS. Sincerel y, Jon Fish 9144 Integra Hills Drive #440 Ooltewah, Tennessee 37363 TheAvalonCompan y@ gmail.com 954

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