## Texas State Drone

William Clay Thompson

12225 Greenville Ave. #700 Dallas, TX 75243

J une 25 , 2015

US Department of Transportation

Federal Aviation Administration 800 Independence Ave. SW Washington, DC 20591

PETITION FOR EXEMPTION, Requesting relief from the FAA

m odernization and Reform Act OF 2012, public law 112

- 95 Feb. 14, 2012,

section 333.

Exemptions Requested for :

14CFR 21, Subpart H

14 CFR 45.23(b)

14CFR 61.113(a)&(b)

14 CFR 91.7(a)

, 91.9(b) (2)

, 91.103(b)

, 91.109, 91.119, 91.121, 91.151(a)

9 1.203(a) & (b)

, 91.405(a), 91.407(a)(1)

, 91.409(a) & (b) , 91.417(a)&(b)

14CFR, Title 14 Chapter 1 Subchapter D parts 60 thru 67, specifically 61.1

to 61.429

.

Contact Information:

William Clay Thompson Owner/UAS Pilot

Texas State Drone

12225 Greenville Ave. #700 Dallas, TX 75243

Phone: 214

- 679

- 8471

TX Driver’s License: 08663130 clay.thompson@yahoo.com

DJI Phantom 2 Vision Plus DJI Inspire 1William Clay Thompson/Texas State Drone, Dallas, TX

- Section 333 Exemption Petition 2

Dear Sir or Madam,

I, William Clay Thompson , am writing pu rsuant to Section 333 of the FAA

Modernization and Ref orm Act of 2012 and 14 CFR Part 11, to request that I, William Clay Thompson, owner and operator of Texas State Drone (TSD), an d

owner and Pilot in Charge of small unmanned aircraft systems (UAS), specifically

the DJI Phantom 2 Vision Plus and the DJI Inspire 1, be exempt from the Federal Aviation Regulations (FARs) listed above so that T e x a s S t a t e D r o n e may operate i t s small UAS’s commercially in ai rs pace regulated by the Federal Av iation Administration (FAA).

I, William Clay Thompson, Pilot in Charge (PIC) and Owner of Texas State Drone (TSD) request this exemption under the guidelines of Section 333 specifically as it relates to aerial videography and photography (commercial and private real estate

, community awareness, and nature ). Under the terms of this exemption TSD agrees to safely fly its UAS's in a safe and lawful manner as it relates to Loca l, State and Federal guidelines as stated within the exemption grant. All UAS's piloted by TSD weight less than 55 lbs and fly at speeds below 58 mph (50 knots). TSD agrees to operate under any and all guidelines set forth by the FAA now and in the future.

TSD follows current FAA regulations, 400 ft. alt itude maximum, line of sight (VLOS), day light only

, and airport 5

- mi l e restrictions. In addition TSD uses a spotter (VO) and 2

- way communication between PIC and visual observer (VO) at all times during the flight. All UAS's owned by TSD are equipped with num erous safety features including auto return to home and low battery functions that return the UAS back to the ground station point of take off. All systems are displayed on 10 inch monitors (battery levels and performance) in addition to altitude, distance

, speed and current GPS location on overlay map. All UAS are maintained according to manufacturer sugg ested maintenance schedules by an authorized dealer.

TSD considers air safety one of our paramount duties to the public. TSD performs a

routine pre

- flight inspection before every flight on every UAS before a launch into the National Airspace System (NAS). These pre

- flight inspections include propellers, motors, battery levels, battery history, compass re

- calibrations, GPS satellite evaluation, ele ctromagnetic conditions, weather and environmental surroundings (structures, power lines, population etc.)

. All of these pre

- flight inspections are performed according to the published manufacturer guidelines as it pertains to the individual UAS.

As the P IC and owner of TSD, I have mu ltiple years and hours flying Remote

Controlled Helicopters and Quad Copters. I also agree, if exemption is granted, to keep a complete flight log ( a s I c u r r e n t l y d o ) to include all required information as

laid out in the FAA exemption (time, date, place, conditions, PIC, VO, etc.)

. As

owner and PIC at TSD

, I will also agree to any required course of study or flight evaluations including fees required if any. I also hold a US passport and have been vetted and accepted by Tra nsportation Security Administration (TSA), DepartmentWilliam Clay Thompson/Texas State Drone, Dallas, TX

- Section 333 Exemption Petition 3

of Homeland Security (DHS)

, and US Department of Immigration and Customs for participation in the Global Online Enrollment System (GOES).

The use of T S D ’ s UA S’s for a erial real estate v ideography is less costly than a helicopter or fixed wing aircraft

. F or small budget real estate companies and average homeowners, the expense of such aerial p hotography and videography is

cost prohibitive. It is my objective to provide this valuable marketing tool to bet ter enhance the sale of real estate at an affordable price by a trained professional with a safety

- first mindset.

Granting T e x a s S t a t e D r o n e an exemption will not adversely affect safety. The public's interest is furthered by minimizing ecolo gical and crash threat by permitting aerial video/photo capture through my battery operated UAS's. The consequence of my UAS crashing is far less than a full sized he licopter or fixed wing aircraft, which are heavy, contain combustible fuel and can cause catastrophic devastation to the public. T S D ’ s UAS’s utilize battery power and have no negative impact on

the environment.

TSD operate s only in reasonably safe environments that are strictly controlled, are away from power lines, elevated lights, airport s, and actively populated areas. I conduct extensive pre

- flight inspections and protoc ols

, during which safety is of primary importance. I always obtain all necessary perm issions prior to operation. I have procedures in pla ce to abort flights in the event of safety breaches or potential danger

. TSD’s safety protocols provide a level of safety equal to or exceeding existing rules

.

When pilot communication is lost, T S D ’ s UAS ’s are designed to return to the point of takeoff, slo wly descend, land, and disengage the electric motors ( r e t u r n t o h o m e f e a t u r e )

. I and T S D will not operate o u r UAS ’s near airports, h ospitals, m ilitary

installations

, or p olice heliports

. I am constantly on alert for any manned aircraft ( personal crafts, p olice/ m edical helicopters, etc.) and am prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location.

TSD’s UAS ’s are ca pable of vertical and horizonta l operations, and are flown only

within P I C ’ s line of sight

.

Regarding pilot certification ( 14CFR

, T itle 14 Chapter 1 Subchapter D parts 60 thru 67, specifically 61.1 to 61.429 ), I, William Clay Thompson, respectfully request the FAA grant exemptions from regulations that address general flight rules, pilot certificate requirements, manuals, maintenance and equipment mandates. I believe that these requirements are unnecessary for pilot controlled drone flight. Additionally, current FAA proposals have omitte d this as a future requirement for

small UAS's.

In Conclusion: T exas S tate D rone and William Clay Thompson submit that given the size and safeguards of t h e afore mentioned UAS's, TSD would be able to perform safe operations greater than envisioned by Congress for the FAA toWilliam Clay Thompson/Texas State Drone, Dallas, TX

- Section 333 Exemption Petition 4

establish. This exemption would allow TSD to perform safe commer cial operations, and in doing so benefiting the greater public interest. William Clay Thompson and TSD wishes you to consider that as to the size of our UAS's, area and altitudes that we fly, this exception would present no risk to our National Security or FAA regulated commercial air space. The strict regulation and operating conditions as provided in Section 333 of the Reform Act gives the FAA the authority to grant this exemption. TSD hopes for a timely consideration as we have made a considerable

inve stment in our time and committed finances.

Kindest Regards,

William Clay Thompson

Owner

Texas State Drone

12225 Greenville Ave. #700 Dallas, TX 75243

Phone: 214

- 679

- 8471

T X Driver’s License: 08663130 clay.thompson@yahoo.com