U.S. Department of Transportation

Docket Operations West Building Ground Floor

RM W12­140

1200 New Jersey Avenue, SE

Washington, DC 20590

To Officer it may concern:

Matthew Hill is requesting the exemption and relief from Part 21, Subpart H; and Sections 45.23(b), 91.7(a),

91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a),

91.407(a)(1),91.409(a)(2), and 91.417(a) and(b) of Title 14, Code of Federal Regulations (14CFR) to be able

to provide video and photo services for our clients.

We seek relief from section 45.23

Marking of the aircraft because our UAS will not have a cabin, cockpit or pilot station on which to mark

certain words or phrases. Two­inch lettering is difficult to place on such a small aircraft with dimensions

smaller than the minimal lettering requirement. Regardless of this, we will mark our UAS in the largest

possible lettering by placing “Experimental” on its fuselage and with as large of lettering as possible as

required by §45.29(f)

We seek relief from 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b)

Maintenance Inspections may be required and should be granted since they only apply to aircraft with an

airworthiness certificate. However, as a safety precaution we will perform a preflight inspection of his UAS

before each flight as outlined in his operating documents.

UAS Pilot in Command (PIC)

Our UAS does not carry any pilots or passengers but we will operate under §61.113 Private Pilot Privileges

and Limitations: Pilot in command. Since our operator is an experienced UAS pilot and paramotor pilot, he

continues to maintain skill and practice on both currently for hobby purposes. For UAS training he has flown

numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain

familiarization with the characteristics of his UAS’ performance under different temperature and weather

conditions.

We seek relief from 1.7(a)

This prohibits the operation of an aircraft without an airworthiness certificate. There is currently no certificate

applicable to our operation, this regulation is inapplicable.

We seek relief from 91.151(a)

Fuel requirements for flight in VFR conditions since our UAS doesn't use fuel but to provide extra safety for

our operation we will fly under 20 minutes per flight when operating. We will take off only with full battery

level and decrease the flight time in cold temperatures below 32 degrees F, and we will not operate below

14 degrees F per UAS manufacturer specifications. We will not begin a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing

point and land the UAS with 30% battery power remaining

We seek relief from 1.121

Altimeter settings is inapplicable since the UAS utilizes electronic GPS with a barometric sensor.
We seek relief from 1.9(b)(2)

This requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on

board his aircraft and given its size, this regulation is inapplicable. We will provide equivalent level of safety

by maintaining a safety/flight manual with the UAS ground station.

Clients we serve are a mix of companies and organizations within’ the United States, including but limited to

the following: manufacturers, video production companies, local government, advertising agencies, and

other individuals and companies.

Granting this exemption to us would allow us to provide this service at a much lower cost and will ensure

operational and legal safety to the individuals of the United States. Using small UAS we will pose no threat

to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. Our

UAS will minimize ecological damage and promote economic growth by providing a taxable service to to our

clients.

We are looking for the exemption and relief from 14 CFR Section to legally and safely provide our service

using UAS in Civil Airspace.

We will operate safely by the following guidelines:

1. We will provide all levels of safety to our operations using FPV (First Person View) autopilot

information at the hands of operator who will have live data information sent from UAS to Remote

Controller as altitude, Ground Speed, Vertical speed, Battery Charge Level, for full understanding of

UAS attitude in flight and time remaining for safe UAS return to take­off point.

2. Fly below 400 feet and remain clear of surrounding obstacles

3. Keep the aircraft within visual line of sight at all times

4. Remain well clear of and do not interfere with manned aircraft operations

5. Won't fly near people or stadiums

6. Won't fly an aircraft that weighs more than 55 lbs

7. Won't be careless or reckless with your unmanned aircraft

8. We will conduct our flight only in Visual Meteorological Conditions conditions and in distance from

clouds described in VFR requirements.

9. We will operate the UAS for less than 20 minutes per flight

10. We use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then

slowly lands if communication with the remote control pilot is lost
11. We will contact respective airports if operations will be within 5 miles to advise them of his estimated

flight time, flight duration, elevation of flight and other pertinent information

12. We will always obtain all necessary permissions prior to operation

13. We will have procedures in place to abort flights in the event of safety breaches or potential danger.

14. We will maintain our current liability insurance policy to include the UAS

15. We will only operate in reasonably safe environments that are strictly controlled, are away from

power lines, elevated lights, airports and actively populated areas; and we will conduct extensive

preflight inspections and protocols, during which safety carries primary importance.

We will use the following UAS: DJI Phantom 3 Professional, Phantom Inspire 1, and 3DR Solo

Regards,

Matthew Hill ­ Owner and UAS pilot in command