# IN FLIGHT

12534 Valley View St. #144 Garden Grove, CA. 92845

April 30, 2015

U.S. Department of Transportation, Docket Management Systems, 1200 New Jersey Avenue SE, Washington, DC 20590

RE: Section 333 Petition for Exemption 14 CFR § 11 .81 Electronic Submittal – Via FDMS Website

Dear Sir or Madam,

This letter serves as a petition for exemption from specific rules contained in Title 14 of the Code of Federal Regulations (14CFR), with regar ds to operation of a small, unmanned aircraft (sUAS) to allow In Flight commercial operation in the industries listed below.

The requested exemption would permit In Flight to pursue its commercial interests in providing services to clients using small advanced sUAS with a focus on the following areas of interest;

• Oil and Gas Infrastructure Monitoring and Inspecti on Services

• Aerial Surveying

• Industrial Facility Inspections

• Conservation Reviews

• General Video and Photography assignments

• Inspection of Wind and Solar power generation

• Inspection of Telecom structures

• Amusement park rides

• Search and Rescue Operations in cases of emergency or natural disaster only when the local authorities or government has reques ted

• Spill response for Oil companies to provide accura te data of incident in real time

In addition to the waiver authority provided in Sec tion 333 of the Modernization Act, the FAA may grant an exemption under 49 U.S.C. Section 44701(f) if it has determined that such an exemption is in the public interest.Each commercial interest has an inherent risk to as sociated tasks performed by

personnel. For example;

Wind power generation – Individuals have to rappel each blade to visuall y inspect. This risk of equipment failure is removed with a sU AS providing the visual inspection. Oil and Gas – Individuals may have to climb high towers and or equipment to do visual inspections. If conducted solo and the individual w ere to fall or have a medical emergency it would be difficult to for Emergency Me dical Service personnel to respond.

With our focus on safety we intend to implement all of the Operational Limitations

, outline in Proposed Part 107 of the Notice of Propo sed Rulemaking (NPRM), at a minimum. These limitations will ensure the same lev el of safety offered by the rules for which the exemption is sought. By adhering to the Operational Limitations , the proposed sUAS operation will minimize risk to the NAS, and t o persons and property on the ground.

The Regulations we are requesting exemption from;

14 CFR Part 21 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.9 (b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 CFR 91.205(b) 14 CFR 91.401 – 91.417

An exemption would allow In Flight to broadly evaluate assets and operations with sUAS, resulting in a safer and more efficient inspe ction and monitoring scheme in the resource industries. The grant of an exemption is c onsistent with Congress’ intent, reflected in Section 333 of the FA Modernization an d Reform Act of 2012, that safe systems be permitted in the national airspace prior to the issuance of final regulations governing general use of these items.

In Flight shall conduct operations with one of the following sUAS: DJI Inspire 1 DJI Phantom DJI S-1000Furthermore, our commitment to safety is foremost i n our operations:

• Personnel will act as an Observer for 20 assignmen ts and will have 10 hours of flight time prior to being given assignments.

• Each assignment will be accompanied by a pre-fligh t check list ( See Attached ).

• Operators shall wear a highly visible vest with wo rding on the back that reads; “Pilot” Do not disturb While in flight

In Conclusion, due to their light weight, sUAS gene rally pose a significantly low risk to people and the property on the ground. The size, we ight, speed, and capability of the DJI product line will not create a hazard to the us ers of the NAS or the general public, nor will it pose a threat to national security. Gra nting this request for exemption would not adversely affect safety, rather it would give o pportunities to reduce risk to the personnel of the industries serviced.

The sUAS’s listed in this request will be registere d with the FAA. Upon award of exemption, a “blanket” 200-foot Certification of Wa iver or Authorization would be requested.

Sincerely,

Timothy Houston Owner, In Flight thouston@inflightca.com