Bradley C. Lorance

8649 Jacksboro Rd

McMinnville, TN 37110

M: 623

- 224

- 7617

E: Lorance11@gmail.com

August 16, 2015

US Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, D C 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

- 2014

- 0508

i n the matter of the petition of ADVANCED AVIATION SOLUTIONS

LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC

Dear sir or madam,

In accordance with the FAA's guidelines for submitting an applic ation for exemption under section 333 of the FAA Modernization and Reform Act of 2012, I Bradley Lorance, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations.

61.113 (a) 61.113 (b ) 91.119 (c)

91.121 91.151 (a) 91.405 (a) 91.407 (a) (1) 91.409 (a) (1)91.409 (a) (2) 91.417 (a) 91.417 (b)

In order to operate small unmanned aircraft systems (UAS) in airspace regulated by the Federal Aviation Administration (FAA) for the purpose of

ae rial photography, videography, survey, mapping, inspections, and other flight operations that may be performed more safely and more cost

effectively with the use of a small UAS at low altitude within the U.S. National Airspace System in comparison to a ma nned aircraft. Operations will be performed only at the request and with the authorization of clients and/or their authorized agents. All such operations shall be conducted within conditions outlined herein or as may be established by the FAA as required b y Section 333.

Requested Exemption

The petitioner hereby requests exemption from the aforementioned FAR's for the following reasons.

61.113 (a)(b) The petitioner requests relief in order to facilitate the utilization of an FAA certified airman, Mr. Brad ley Lorance, who holds a Private Pilot certificate

and a current and valid class 3 medical certificate. Mr. Lorance would be required to comply with any conditions set forth and as in a similar fashion as to the previously granted exemptions.

91.119 (c)

A s discussed in exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UAS be operated closer than 500 feet to essential personnel or objects that would not be possible without additional relief. The petitioner requests modification, waiver, or exemption and clarification concerning the terms "congested areas" and "densely populated". The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of housing su bdivisions and neighborhoods as required.

91.121 As discussed in exemption 11138 (DOUGLAS TRUDEAU) is inapplicable as the UAS does not have an altimeter and instead, will use GPS data for

altitude data.

91.121As discussed in exemption 11136 (ADVANCED AV IATION SOLUTIONS, LLC) prior relief has been granted for manned aircraft to operate at less than prescribed minimums including exemption numbers 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in exemption numbers 8811, 108 08, and 10650 for daytime VFR conditions. The UAS will provide battery power remaining data reflected as percentage of capacity to the PIC. The UAS batteries provide approximately twenty five minutes of powered flight. Information provided in the operating documentation discusses procedures regarding remaining battery power management. These documents contain a condition in which the PIC will land the aircraft when the battery power remaining reaches the

minimum level that will allow a safe return and landi ng of the aircraft. Given the limitations on proposed operations and the location of those proposed operations, the FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable.

91.405 (a) 91.407 (a)(1) 91.409 (a)(1)( 2) 91.417 (a)(b) As discussed in exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance to the operating documentation. The FAA found that adherence to the operating doc umentation and the conditions and limitations specified therein, describing the requirements for maintenance, inspection, and record keeping were sufficient to ensure that safety would not be adversely affected.

The UAS

The aircraft proposed by the petit ioner is the DJI Flame Wheel 550. The DJI Flame Wheel 550 is a small rotorcraft in the hexacopter configuration with an advertised weight of 2400g designed primarily to carry aloft a high definition camera. It has an advertised diameter of 550mm and is pow ered by six electric motors. It uses an advanced flight stabilization system and GPS in order to accurately hold position. It also has altitude limiting software as well as a flight radius limiting function which prevents the aircraft from exceeding altit ude and distance from ground station limits.

There is a ‘return to home’ function as well. If communication with the aircraft is disrupted, the onboard computer will automatically send the aircraft back to its home position immediately where the pilot can attempt to regain link and arrange for a safe recovery of the aircraft. In addition, the PIC can initiate the return to home function by flipping a switch. Theaircraft will be controlled primarily through a standard FCC certified model

aircraft transmitte r. Real time video and telemetry information are transmitted back to a ground control unit allowing the operator and observer to monitor battery level, GPS signal strength, altitude, distance from PIC, camera imagery and control camera angle. Battery life limits flight times to approximately 25 minutes or less. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state.

Risk Mitigation

The petitioner has reviewed FAA exemptions referen ce's 13 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified before launch. A visual observer will be utilized in order to provide a high level of situational awareness. Liability insurance will be obtained commensurate with the granting of this request for exemption. Airwo rthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components. The petitioner requests that in a manner similar to reference 3, he be allowed to oper ate within five miles of an airport provided that:

"The UA may not operate in class B, C, or D airspace without written approval from the FAA. The UA may not operate within five nautical miles of the geographic center of a non

- towered airport as denoted o n a current FAA published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement with the airport mana gement must be made available to the Administrator upon request."

Operations within five miles of an airport are not anticipated to be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need

arise.

Public Interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operationsconducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to facilitate commerce can lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level photography/videography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased use of pesticides and fertilizer and conservation of water as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase worksite efficiency, improve volumetric estimatio ns, and reduce risks. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. Flight data including UA flight time, control unit operation time, incident, accident, and detail s concerning any deviation from normal operations will be available to the FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via traditional means, e.g. COA Monthly Reports, or other mean s as required.

Conclusion

The petitioner is requesting this exemption for the purposes of aerial photography, videography, mapping, crop surveying, inspections and other flight operations. The request for several uses of the UAS is to allow for

future de mand to be met without the need for additional exemptions to be filed. There is already a high demand for real estate photography, crop surveying, and aerial inspection of property. Use of a UAS would ultimately provide a tool that is far safer, more cost effective, and more timely than other methods. The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance with the FAA regulations.

Summary

The petitioner requests exemption for himself , Bradley C. Lorance, from Title 14, Code of Federal Rules pertaining to the safe, commercial usage of unmanned aerial systems (UAS) in controlled secured video and photographic production areas. Exemption from sections of CFR part 61.113(a)(b), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a)(b) are requested. The petitioner supports his request with the following information. 1. Unmanned Aircraft System (UAS); this section describes the UAS capabilities and the failsafemechanisms that are programmed into the UAS; 2. Risk Mitigation; this section describes proposed safety measures to be utilized in order to mitigate risk to persons and/or property including operational procedures and areas of flight to be taken i nto consideration; 3. Public Interest; this section outlines the advantages of UAS operations to both the particular customer and the population as a whole.

Sincerely,

Bradley Lorance