Petition 

### for 333 Exemption 

### Petitioner LONNIE P DUPONT 242 BACKSTEP ROAD PLAUCHEVILLE 

### IA7T362 318-305-7380

lonnie d up o nt@gm a i l, com

U.S. Department ofTransportation, Docket Operations West Building, Ground Floor, Room

W12-14o 1200 New Jersey Avenue, SEWashington, DC 20590

Description of Relief Sought: The 

### petitioner isseeking an exemption 

### to comrnercially operate its unmanned aircraft in UAS compliance 

### for aerial photography/videography of 

### public/private events, television operations, agricultural inspections, structural inspections, real estate photography/videography and

### to assist law enforcement, 

### first responders and

### other public agencies in search and rescue operations.

Re: Exemption Request Pursuant 

### to Section 333 of

### the FAA Reform Act and Part 11 of

### the Federal Aviation Regulations 

### from: 14 CFR21 subpart H; 14 CFR45.23(b); 14 CFR 61.113(a) and (b); 1f,' cFR91.7(a); 14 cFR91.9(bX2); 14 cFR91.103; 14 cFR 91.109; 14 CFR91.119(c); 14 CFR 91.121; 14 CFR91.1s1(a); 14 cFR 91.203 (a) and (b); 14 cFR91.40s (a); 14 CFR 91.ao7 (a) ( ) 14 CFR 91.a09 (aX1) and (2); 14 CFR 91.417(a) and (b).

Dear Siror Madam: Pursuant 

### to Section 333 of

### the 

### FM Modernization and Reform Act 

### of 2012 (the "Reform Act") i and 14 CFR Part 11, Lonnie P Dupont, operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from 

### the listed Federal Aviation Regulations ("FARs") 

### to allow commercial operation 

### of its UAS, so long as such operations are conducted 

### within and underthe conditions 

### outlined herein or as may be established by

### the FAA as required by Section 333

Commercial operation of an UAS, as described herein,which are equipped 

### with camera(s) and sensors, would operate inthe 

### following manner: 1.Aerialvideo/photography or providing live video feed

### to assist 

### with search and rescue operations in cases of an emergency or natural disaster onlywhen 

### the local authorities 

### or

government has requested 

### it by contract or donation. 

### 2. Aerial photography 

### and/or video 

### for public 

### and/or private use including real estate, architecture, land 

### surveying engineering and 

### other related professional activities. 4. Aerial video 

### and/or photography 

### for public 

### and/or private use including television, public events, cinematography and news gathering. 5.Aerial inspection/photography 

### of residential/commercial 

### utility infrastructure including 

### but

not limited 

### to electrical power lines-,wind turbines and cell towers. As described 

### fully below, 

### the requested exemption 

### would permit the operation of a UAS under controlled conditions in

### the NAS

### that would be 

### limited, controlled, predetermined and

### will provide safety enhancementsto 

### the already safe operations in

### the industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and

### fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities 

### to " establish requirements for 

### the safe operation of such aircraft systems in

### the national airspace system"

Regulations 

### from which the exemption is requested

14 CFR Part 21 subpart H 14 CFR45.23 (b) 1a cFR61.113 (a) & (b) 14 cFR 91.7 (a) 14 cFR e1.s (b) (2) 14 CFR91.10314 CFR91.109 14CFR91.119(c) 14 CFR91.121 14 cFR 91.151 (a) 1a cFR91.203 (a) & (b) 14 cFR91.4os (a) 14 cFR91.407 (a) (1) 1a cFRs1.a09 (a) (2) 1a cFRs1.417 (a) & (b) Lonnie P Dupont

### will operate the

### following aircraft:

DJI PHANTOM 3 PROFESIONAL WEIGHT: 1280 grams(battery included), MAX SPEED: 16 m/s, GPS enabled 

### with Return 

### to Home Failsafe, Max 

### Altitude of 120 meters preset insoftware. Battery: 15.2volt 4480 mah capable 

### of approx. 23 minute 

### flighttime.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY Theoperation 

### limitations proposed 

### for an equivalent or higher level of safety because operations will 

### further enhance the safety of

### the persons 

### and/or property using conventional aircraft. These 

### limitations and conditions to which the applicant agrees 

### to adhere 

### to when conducting

commercial operations under

### the FAA issued exemption include:

1.The UAS

### will weigh less than 55 lbs. 2.The UAS

### will have a maximum operating speed of no more 

### than 16 m/s 3. Flights 

### will be operated 

### within line of sight of

### the Pilot in Command (PlC) and/or Visual Observer (VO). The applicant 

### will operate 

### the UAS in line of sight 

### within a closed 

### off and predetermined area owned and/operated by

### the property representative. 4" Maximum 

### flight time 

### for each operational 

### flightwill be 20 minutes. Flights 

### will be

### terminatedat 25% battery power reserve or 20 minutes of

### flighttime whichever occurs

### first.

5. Flights 

### will be operated at an altitude 

### of no more than 40o feet Above Ground Level (AGL) and not more than 200feet above an elevated 

### platform from which

### filming is planned. 6. 

### Minimum crew 

### for each operation 

### will consist of

### the UAS Pilot, the Visual Observer (VO) and may include 

### but not limited 

### to a Camera Operator. 7. A briefing 

### will be performed regarding 

### the planned UAS operations prior 

### to each day's

### flight consisting of all the'days' production activities. 8.All flights 

### will occur underVisual FIight Rules Meteorological Conditions (VMC) only. 9. lf operations 

### will be

### within a 5 mile radius ofthe geographic 

### center/Airport Reference Point (ARP) of a

### tower controlled or uncontrolled 

### airportthe respective airports 

### will be contacted advising them of the estimated 

### flight time, 

### flight duration, elevation of

### flight and 

### other pertinent information. 

### Airport common 

### traffic frequency or control 

### tower frequency 

### will be 

### monitored during operations. 

### 10. The operator 

### will obtain 

### verbal/written consent of all persons involved 

### with the planned operation and ensure 

### that only consenting persons 

### will be allowed 

### within 30

### feet ofthe 

### flight operation. With the advanced permission of

### the FSDO, operations at closer range may be approved. 11.The PICand VO

### will have been

### trained inoperation 

### of UAS and receive uP-to-date

information for 

### the particular UAS 

### to be operated. 12. The PIC and VO

### will be able 

### to communicate by voice, radio, 

### and/ortext at alltimes. 13. 

### Written and/or verbal permission and permits as appropriate 

### will be obtained 

### from territorial, state, county or city jurisdictions, including law enforcement, 

### fire or 

### other appropriate governmental agencies. 14. lf

### the UAS loses communications 

### with the remote 

### controller or loses GPS signal,

### the UAS

### will have 

### the capability

### to return 

### to a per-determined location 

### within adesignated locatlon and land autonomously. 14 C.F.R. Part 21, Subpart H:Airworthiness Certificates 14 C.F.R.991.203 (a) (1) Subpart H,

### entitled Airworthiness Certificates, establishes 

### the procedural requirements for 

### the issuance of airworthiness certificates as required by FAR $91 .203 (a) (1). Given the size and 

### limited operating area associated 

### with the aircraft 

### to be utilized by the Applicant, an exemption 

### from Part 21 Subpart H meets 

### the requirements of an equivalent level of safety under Part 11 and Section 333

### ofthe Reform Act. The FederalAviation Act (49 U.S.C.544701 (f)) and Section333 of

### the Reform Act both authorize 

### the FAA

### to exempt aircraft 

### from the requirement 

### for an

airworthiness certificate. upon consideration of

### the size,weight, speed, operational capability, and proximity 

### to airports and populated areas of

### the particular UAS. ln all cases, an analysis 

### of these criteria demonstrates 

### thatthe UASoperated 

### without an airworthiness certificate, in

### the restricted environment and under the conditions proposed

### will be at least as safe, or safer, 

### than aconventional aircraft (fixed wing or 

### rotorcraft) operating 

### with an airworthiness 

### certificate

without the restrictions and conditions proposed. The uAs

### to be operated hereunder is less than 55 lbs. 

### fully loaded, carries neither a

### pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

### within asecured and designated area. Unlike other civil aircraft, operations under 

### this exemption 

### will be

### tightly controlled and 

### monitored by both the operator and underthe requirements and in compliance

### with local public safety requirements. The 

### FM will have advance notice of all operations. These safety enhancements provide agreater degree of safety 

### to the public and property owners than conventional operations conducted 

### with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates 

### that there is no credible

### threat 

### to national security posed by

### the UAS, due

### to its size, speed of

### operation, location of operation, lack of explosive materials or flammable liquid

fuels, and inability 

### to carry a-substantial external load. 14 C.F.R. S45.23 (b). Marking ofthe 

### Aircraft

The regulation requires: When marks include only

### the Roman capital 

### letter "N" and

### the registration number isdisplayed on 

### limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft, the 

### operator must also display on 

### that aircraft near each entrance 

### to the cabin, cockpit, or 

### pilot station, in letters 

### not less

### than 2 inches nor more than 6 inches high, the words 

### "limited, restricted, light-sport, experimentat or provisional " as 

### applicable' Eventhough 

### the UAS

### will have no airworthiness certificate, an exemption may be needed 

### asthe UAS

### will have no entrance

### to the cabin, cockpit or 

### pilot station on which the

### word "Experimental" can be placed. Given

### the size of 

### the uAs, 

### two-inch letteringwill be impossible. The

### word "Experimental" 

### will be placed onthe fuselage in compliance

### with 945.29 

### (f). The equivalent level of safety

### will be provided by having 

### the UAS marked on its fuselage as required by 

### 945-29 (f)where

### the pilot, observer and others working 

### with the UAS

### will see

### the identification of

### the UAS as "Experimental" 14 C.F.R.9 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant 

### to 14 CFR 61.113 (a) 

### & (b), no person who holds a private 

### pilot certificate may act as a 

### pilot in command of an aircraft 

### that is carrying passengers or property 

### for compensation or hire. Petitioner may achieve an equivalent level of safety as achieved by 

### current Regulations becausethe applicant's UASdo not carry any pilots or passengers or property- The risks attendant 

### to the

operation 

### of UAS isfar less than 

### the risk levels inherent inthe commercial activities outlined in 14 CFR 61. The PICof 

### the UAS

### will have Commercial Pilot's License along 

### with acurrent Second Class or higher Medical exceeding the current safety levels in relation 

### to 14 CFR 61.113 (a) 

### & (b). Ifeel the operation and limitations 

### will equate

### to the safe operation of

### the UAS.

14 C.F.R. 591.7(a): Civil Aircraft Airworthiness. The regulation requires 

### that no person may operate a civil aircraft unless 

### it is in 

### airworthy condition. As there 

### will be no airworthiness certificate issued for 

### the aircraft, should this exemption be granted, no 

### FM regulatory standard

### will exist for determining airworthiness. Given

### the size of

### the aircraft 

### for maintenance and use of safety check lists prior

### to each 

### flight an equivalent level of safety 

### will be provided. 4 C.F.R. 5 91.9 (b) (2): Civil 

### Aircraft Flight Manual inthe 

### Aircraft Section 91..9 (b) (2) provides: No person may operate a U.S.-registered 

### civil aircraft. (2) For which anAirplane or Rotorcraft Flight Manual is 

### not required by $21 .5 ofthis chapter, unless 

### there is available in

### the aircraft acurrent approve-d airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and 

### configuration has no ability or place 

### to carry such a

### flight manual on

### the aircraft, 

### not only because 

### there is not 

### pilot on board, but because 

### there is no room or capacity 

### to carry such an item onthe aircraft. The equivalent level of safety 

### will be maintained by keeping the 

### flight manual atthe ground I

### control point where 

### the pilot flying 

### the UAS

### will have immediate access 

### to it14 C.F.R. $91.103: PreflightAction. This regulation requires each 

### pilot in command

### to take certain actions before

### flight

### to insure 

### the safety of

### flight. As FAA approved 

### rotorcraft flight manuals 

### will not be provided for the 

### aircraft an exemption 

### will be needed. The PIC

### will take all actions under Normal Procedures including but 

### not limited 

### to reviewing weather, 

### flight battery requirements, landing and

### takeoff distances and aircraft performance data before 

### initiation of

### flight. 14 C.F.R. 991.109: Flight 

### lnstruction Section 91.103 provides 

### that no person may operate a civil aircraft (except a manned free balloon)

### that is being used for 

### flight instruction unless 

### that aircraft has fully functioning dual controls. UAS and 

### remotely piloted aircraft, by

### their design do not havefully functional dual controls. Flight 

### control is accomplished through 

### the use of a

### control box

### that communicates 

### with the aircraft via radio communications. The FAA has approved exemptions 

### for flight 

### training

### without fullyfunctional dual controls 

### for a number of aircraft andfor 

### flight instruction in

experimental aircraft. The equivalent level of safety provided by the fact 

### that neither a 

### pilot nor passengers 

### will be carried inthe aircraft and by

### the size and speed ofthe aircraft. 14 C.F.R.991.119; Minimum SafeAltitudes. Section 91.119 establishes safe altitudes 

### for operation of civil aircraft Section 91.119 (d) allows, helicopters 

### to be operated at less than 

### the minimums prescribed, provided

### the person operating 

### the helicopter complies 

### with any route or altitudes prescribed 

### for helicopters by

### the FAA. Asthis exemption is

### for a UAS 

### that is a helicopter and 

### the exemption requests 

### authority

### to operate 

### at altitudes up

### to 400 AGL,or not more than 200 above an elevated platform 

### from which

### filming is planned an exemption may be needed 

### to allow such operations. As set

### forth herein,

### the UAS

### will never operate at higher than 400 AGL

### with the exception 

### that in circumstances where 

### the UAS is used 

### to survey or photograph astructure whose height exceeds 400 feet AGL,

### the UAS

.

### ltwill not be operated more than 200

### feet above 

### the highest point on 

### the structure. lt

### will however be operated in a restricted area 

### with security perimeter, where buildings and people 

### will not be lexposed 

### to operations 

### without their pre-obtained consent. The equivalent level of safety

### will be achieved given 

### the size,weight, speed of

### the UAS aswell as

### the location where 

### it is operated. No 

### flightwill b:etaken 

### without the permission of

### the property owner or local officials. Because ofthe advance notice to 

### the property owner and participants inthe filming activity, all affected individuals 

### will be aware of 

### the planned 

### flight operations. Compared 

### to flight operations 

### with aircraft or 

### rotorcraft weighting far more than 

### the maximum 551bs. proposed herein and 

### the lack offlammable fuel, any risk associated 

### with these operations isfar less thanthose presently presented 

### with conventional aircraft operating at or below 500

## ft AGL. lnaddition, 

### the low-altitude operations 

### ofthe UAS

### will ensure separation between

### these UASoperations and the operations of conventional aircraft 

### that must comply

### with Section ' 91.119. 14 C.F.R. 591.121 

### Altimeter Settings. This regulation requires each person operating an aircraft 

### to maintain cruising 

### altitude by reference 

### to an

### altimeterthat is

### set to the elevation 

### ofthe departure 

### airport or an appropriate 

### altimeter setting available before departure. As

### the UAS may 

### not have a barometric 

### altimeter, but instead a GPS 

### altitude read out, an exemption may be needed. An equivalent level of safety 

### will be achieved bythe 

### operator, pursuantto the safety check list and live

### flight data monitoring, confirming the altitude of 

### the launch site shown on the GPS 

### altitude indicator before

### flight. 14 C.F.R. 

### I91.151(a); Fuel Requirements 

### for Flight in VFR Conditions Section 91.151 (a) prohibits an Individual 

### from beginning a

### flight in an airplane under VFR conditions unless (considering wind andforecast weather conditions) 

### there isenough fuel

### to

### fly

### to the

### first point of intended landing, and, assuming normal cruising speed (1) During the day,



### to fly after 

### thatfor at least 30 minutes; or (2) At night,

### to fly after 

### that for at least 45 minutes. The battery powering 

### the UAS provides approximately 3O minutes of powered flight. To 

### meet the 30 minute reserve requirement in 14 CFR S91.151, UAS flights would be limited 

### to approximately 10 minutes in length, Given

### the limitations on 

### the UAS's proposed 

### flight area and 

### the location of its proposed operations 

### within a predetermined area, a longer time frame 

### for flight indaylight or

### twilight VFR conditions is reasonable. Applicant believes 

### that an exemption 

### from 14 CFR 991. 151 (al falls 

### within the scope of prior exemptions. Operating

### the UAS, in a 

### tightly controlled area where only people and 

### property owners or 

### official representatives who have signed waivers 

### will be allowed, 

### with less than 30 minutes 

### of reserve fuel, does 

### not engender the type of risks 

### that Section 91,151 (a)

### was intended 

### to alleviate given the size and speed ofthe small UAS. Additionally, 

### limiting UAS flights 

### to 10 minutes would greatly reduce 

### the utility for which the exemption 

### will be granted. Applicant believes 

### that an equivalent level 

### of safety can be achieved by limiting flights 

### to 30 minutes or 25% of 

### battery power-whichever happens first. This. restriction would be more than adequate

### to return 

### the UAS

### to its planned landing zone

### from anywhere in its 

### limited operating area.

14 C.F.R. 991.203 (a) and {b): Carrying Civil Aircraft Certification and Registration The regulation provides in 

### pertinent part: Except as provided in$ 91.715, no person may operate acivil aircraft unless 

### it has 

### within itthe

### following: (1IAn appropriate and current 

### airworthiness certificate. (b) No person may operate a civil 

### aircraft unless 

### the airworthiness 

### certificate required by paragraph (a)ofthis section or aspecial

### flight authorization issued under 991. 715 isdisplayed atthe cabin or cockpit entrance so

### that 

### it is legible 

### to passengers or 

### crew. The UAS

### fully loaded weighs no more than 551bs. and isoperated 

### without an onboard pilot. As such, 

### there is no ability or place 

### to carry 

### certification and registration documents or

### to displaythem on

### the UAS. An equivalent level of safety 

### will be achieved by keeping these documents atthe ground 

### control point where the 

### pilot flying

### the UAS

### will have immediate access to them, 

### to the extent they are Iapplicable to 

### the UAS.

14 C.F.R. $91.405 (a); a07 {a) (1}; a09 (a) (2); a17(a) & (b): Maintenance lnspections These regulations require 

### that an aircraft 

### operator or owner shall have

### that aircraft inspected as prescribed insubpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 of

### this 

### chapter...," and others shall inspect or maintain 

### the aircraft in compliance

### with Part 43- Given 

### that these section and Part 43 applv only

### to aircraft 

### with an airworthiness 

### certificate, these sections 

### will not apply to 

### the applicant. Maintenance 

### will be accomplished bythe 

### operator pursuant

### to the

### flight manual and operating handbook. An equivalent level of safety 

### will beachieved because 

### the UAS isvery 

### limited in size and

### will carry asmall payload and operate only

in restricted areas 

### for a 

### limited period of

### time. lf mechanical issues arise

### the UAS can land immediately and

### will be operating 

### from no higher than 4@ feet AGL Theoperator 

### will ensure 

### thatthe UAS is inworking order prior 

### to initiating 

### flight, perform required maintenance, and keep aJog of any maintenance performed. Moreover, the 

### operator is

### the person most

### familiar with the aircraft and best suited

### to maintain the aircraft in an

### airworthy condition 

### to provide the equivalent level 

### of safety. An equivalent level of safety

### will be achieved because maintenance and inspections 

### will be performed in accordance 

### with the UAS 

### Manufacturers User Manual. The operator 

### will ensure 

### that the UAS is inworking order prior 

### to initiating 

### flight and 

### perform required maintenance as needed. Additional 

### lnformation The applicant has been flying and building UAS 

### for approx. 3years and has agreat deal 

### of knowledge in

### their inner workings, construction, maintenance and most 

### importanttheir safety concerns, Satisfaction of criteria provided in Section 333 of

### the Reform Act of 2012 provide more 

### than adequate 

### justification for the grant of

### the requested exemptions allowing the commercial operation ofthe applicant's UAS. Giventhe small size

### ofthe UAS andthe controlled 

### environment provided

### the proposed operations will adhere 

### to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding 

### the level of safety surrounding 

### the proposed operations and 

### the public benefit, reduction in environmental impacts, including but not 

### limited 

### to reduced emissions and noise, professional and private user education, the grant of

### the requested exemption is in

### the public interest. 

# t'n'zrlt

# - \ fl 

# -A:l.54*

Lonnie P Dupont