To: U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room Wl2-140 1200 New JerseyAvenue, SE Washington, DC 20590

From: PeterWagner 18 Turkey Trot Road New Milford, CT 06776 860-354-9151 wagner.peter@gmail.com

Amendmentto: Public Docket (No. FAA-2015-0978)

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.P.R. Part 11, PeterWagner, an individual, seeks exemption from requirements of14 C.F.R. § 21, Subpart H; 14 C.F.R. § 43.11; 14 C.F.R. § 91.103; 14 C.F.R. § 91.105; 14 C.F.R. § 91.109; 14C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.P.R.§ 91.405(a) and (d); 14 C.P.R.§ 91.407(a)(l); 14 C.F.R. § 91.409(a)(2); 14 C.P.R.§ 417(a) and (b) to operate an unmanned aerial vehicle (UAV) (a DJI Phantom 3 Pro) in supportofcommercial aerial photography and videography ofindividual commercial, public, and residential properties and structures with owners/operators permission and appropriate authorization.

The request for this exemption is in the Public Interestas there are manyconsumer applications for the services that can be provided by UAVthat are currently conducted by manned aircraft. Using a UAV for many ofthese applications creates

an environmentallyfriendly, lower cost solution to both the operator and consumer. These aircraft can be operated safely, and without significant financial impactto the operator or any person orproperty on the ground in the event ofthe loss ofan aircraft. Utilizing these UAVwill create a safe and more productive work environment, reduce environmental pollution and have a positive impact on the local economy, which is in the Public Interest.

PeterWagner respectfully requestthatthe FAA grantthe following requested exemptions:

14 C.P.R.§ 21, SubpartH; 14 C.P.R.§ 43.11; 14 C.P.R.§ 91.103;14 C.P.R.§ 91.105; 14 C.P.R.§ 91.109; 14 C.P.R.§ 91.119; 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.151(a); 14 C.P.R.§ 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); 14 C.F.R. § 417(a) and (b).

14 C.P.R. 21, Subpart H: Airworthiness Certificate PeterWagner requests an exemption from 14 C.P.R. 21, Subparti·L This Subpart establishes the procedures for the issuance ofan airworthiness certificate. Peter Wagner requests an exemption from Part 21, Subpart Hbecause the UAV (DJIPhantom 3 Pro) is under 50 pounds (including payload) and meets an equivalent level ofsafety pursuantto Section 333 ofthe Reform Act due to its small size, light weight, and restricted operating environment.

14 C.F .R 43.11: Records for Inspections PeterWagner requests an exemption from 14 C.P.R. 43.11. This partprovides that maintenance record entries be maintained, thatthe inspector listdiscrepancies, and to affix placards to the aircraft. Due to its small size the UAV proposed for use, does not have room for placards to be placed in or on it and no inspections for UAV have been certified by FAA atthe presenttime. However, as a conditionto the grant ofthe exemption, PeterWagner will perform the inspections and time replaceable items recommended by the manufacturer and keep records and log books ofall maintenance and repairs.

14 C.F .R 91.103: PreflightAction PeterWagner requests an exemption from 14 C.F .R. 91.103. This regulation requires each pilotto take certain actions before flight to insure the safety offlight. As FAA approved flight manuals will notbe provided for the UAV, an exemption is needed. Peter Wagner will follow the manufactures preflightinspection.

14 C.F.R 91.105: Flight Crewmembers at Stations PeterWagner requests an exemption from 14 C.F .R. 91.105. PeterWagner requests

an exemption from 14 C.P.R. 91.105 since this part is not applicable due to the UAV carrying no flight crewmembers. An equivalentlevel ofsafety will be maintained by ensuring the pilot does not change inflight.



### SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER
Department ofTransportation Federal Aviation Administration Petitioner: PeterWagner Petition ofexemption from sections of; 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121,91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) Description ofreliefsought; PeterWagner seeks an exemption for commercial operation ofan unmanned aerial vehicle thatis under 50 pounds including payload. The unmanned aircraft vehicle has an onboard camera system capable ofacquiring high resolution data. Proposed operations will offer real estate aerial photography, videography and aerial surveying services for other commercial industries.
Respectfully submitted,