01 Sep 2015

Jonathan LaQuay 243 Riverdale Ct #432 Camarillo, CA 93012 (916) 690

- 1679 jmlaquay @yahoo.com Subject: Petition for Exemption Under Section 333
References: (a) DJ I Inspire 1 User Manual

(b) DJ I Inspire 1 Maintenance Manual **Purpose:** Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) , and 14 C.F.R. Part 11, I , Jonathan LaQuay , henceforth known as the petitioner, hereb y appl y for an exemption from the Federal Avi ation Regulations (FARs) listed below to allow the operation of the DJIInspire 1 Small Unmanned Aircraf t S ys tem (sUAS) commercially in airspace regulated b y the Federal Aviation Administration (FAA)

. This grant of exe mption will permit me to operate the sUAS for commercial photograph y, videography , and live

- feed purposes. **Exemption is requested from the following:**
14 C.F.R. Part 21 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2) 14 C.F.R. 91.119 (b)(c) 14 C.F.R. 91.121 14 C.F.R. 91.151 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91 Subpart E **Description of relief requested, reasoning, and equivalent level of safety:**
14 CFR Part 21 : Airworthiness C ertificates : Subpart H establishes the procedural requirements fo r the issuance of airworthiness certificates as required b y FAR §91.203(a)(1). Given the size , weight, speed, and operational capability of the sUAS , an exemption from Part 21 is requested. The proposed exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC §4 4701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requireme nt for an airworthiness certificate, upon considerat ion of the s ize, weight, speed, operational capability and proximity

to airports and populated area s of the particular s UAS. T he s UAS operated w ithout an airworthiness certificate, within the conditions and limitations of the proposed grant , will be at le ast as safe, or safer, thana conventi onal aircraft operating with an airworthiness certificate not within the conditions and

limitations of the proposed grant

. 14 CFR 91.7(a): Civil A ircraft A irworthiness : Part 91.7(a) requires that no person operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issue d for the sUAS the petitioner will operate , should this exemption be granted, no FAA regulatory standard will exis t for determining airworthiness; there fore, an exemption from Part 91.7(a) is requested. Given the size , weight, speed, and operational capability of the sUAS , an equivalent lev el of safety will be maintained. 14 CFR 91.9(b)(2): Civil Aircraft F light M anual, M arking and P lacard R equirements : Part 91.9 outlines the requirements to carry flight manuals and other applicable documents in the aircraft. Since the s UAS, given its size and configuration , has no ability to carry documents i n the aircraft, an exemption from Part 91.9(b)(2) is requeste d. The equivalent level of safety will be maintained b y keeping the operating m anuals at the ground control point where the petitioner will have immediate access
. 14 CFR 91.103: Preflight A ction : Part 91.103 requires each pilot in command to take c ertain actions before flight to ensure the safet y of flight. An exemption is requested from Part 91.103, as the petitioner will take separate preflight actions, including checking weather conditions, TFRs, NOTAMS, battery levels , and all other actions in accordance with reference (a) applicable to sUAS operations

. These actions will p rovide an equivalent level of safety to the preflight actions outlined in Part 91.103.
14 CFR 91.119 (b)(c) : Minimum Safe A ltitudes : Part 91.119(b) provides that no aircraft may operate below an altitude of 1,000 feet above the highest obstacle within a horizontal radiu s of 2,000 feet of the aircraft while o ver an y congested area of a city , town, or settlement, or over any open air assembl y of persons

. Part 91.119(c) provides that no aircraft may operate below an altitude of 500 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. Given the size, weight, speed, and operational capability associated with the sUAS to be utilized by the petitioner , an exemption from Part 92.119(b)(c) is requested. Preflight planning, maintaining Visual L ine of Sight (VLOS) with the sUAS, and operating the sUAS over private property or persons only with prior consent will ensure that an equivalent level of safety to the minimum safe altitude provision is maintained. Additionally , the sUAS will operate at or below 400’ AGL in VMC conditions. 14 CFR 91.121: Altimeter Settings Part 91.121 requires each person operating the aircraft t o maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS is not equipped with a barometric altimeter, but instead a GPS altitude read o ut, an exemption to Part 91.121 is requested. An equivalent level of sa fety

will be achieved by

the petit ioner confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 CFR 91.151(b ): Fuel R equirements for F light in VFR C onditions :Part 91.151(b ) provides that a rotorcraft must maintain enough fuel to be able to fly for 20 minutes after the intended point of landing is reached while fl yi ng under VFR cond i tions. Since the full battery

capacit y of the sUAS provides for approximately 15

- 20 minutes o f flight, an exemption to Part 91.151(b) is requested. Return to Home Point failure mode software ensures that the sUAS is returned to the preset home way point and landed before the sUAS runs out of battery power. This logic is continuously updated based on aircraft position and altitude. Additionally , aircraft battery level remaining is displayed on the control ler and an alert tone warns the operator when power remaining reaches a preset low

- battery level. The described software features, proper planning, and operating the sUAS in a regime in which a safe landing may be made at a moment’s notice ensure that an equivalent level of safety reached with Part 91.151(b) is maintained.
1 4 CFR 91.203(a)(b) : Civil Aircraft : Certification s Required : Part 91.203(a)(b) outline the requirements for civil aircraft to carry certifications. Since the s UAS, given its size and configuration , has no ability to carry documents in the aircraft, an exemption from Part 91.203(a)(b) is requested. The equivalent level of safety will be maintained by

keeping applicable certifications at the ground control point where the petitioner will have immediate access
. 14 CFR 91 Subpart E : Maintenance, Preventative Maintenance, and Alterations: Part 91 Subpart E outlines the regulations governing the maintenance, preventive maintenance, and alterations of U.S.

- registered civil aircraft operating within or outside of the United States. Given the unique size , weight and configuration of the sUAS, an exemption to Part 91 Subpart E is requested. An equivalent level of safety will be provided b y maintaining and the sUAS i n accordance with reference (b) and performing preflight actions as previously discussed.
**Public B enefit**  Approval of exemptions allowing commercial operation s of sUAS for aerial photograph y, videograph y, and live

- feed purposes enhances safety while reducing risk. Replacing a manned aircraft with a sUAS completely eliminates the risks to which pilots are commonly subjected

. The use of sUAS enables the viewing of areas from a separate, safe location, which eliminates the risk of a human accessing those same areas. P ropert y and personnel damage due to an aviation mishap is far less extensive with a sUAS compared to a manned aircraft. Additionally , commercial applications of sUAS enjoy the same, if not better, results than from those of a manned aircraft at a fraction of the cost. **Equivalent Level of Safety** Robust safety

features inherent in sUAS software, the size, weight, speed, and operational capability of sUAS ensure that, when properl y controlled, sUAS are a safe replacement for manned aircraft. Additionally , conditions and limitations placed on civil sUAS operations provide an equivalent level of safety to the existing regulatory structure.
**Additional Information:** The petitioner holds a commercial license, instrument rating and operates public UAS for the U.S. Navy

.The petitioner would like to exer cise the privileges of the proposed exemption outside of the

United States in order to supply commercial services in locations outside of the United States. **Summary** Petitioner: Jonathan LaQuay Exemption requested from the following: 14 C.F.R. Part 21 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2) 14 C.F.R. 91.119 (b)(c) 14 C.F.R. 91.121 14 C.F.R. 91.151 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91 Subpart E Description of relief s ought: The petitioner is seeking exemption from th e abov e listed FARs under Section 333 of the FAA Reform Act to allow the operation of the DJ I Inspire 1 sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) . This grant of exemption will permit the petitioner to operate the sUAS for commercial photogra phy , videography , and live

- feed purposes.
Most Respectfully , Jonathan L aQuay 243 Riverdale Ct #432 Camarillo, CA 93012 (916) 690

- 1679 jmlaquay @yahoo.com