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### Spectre Aerial Productions, LLC 202 Teakwood St Lake Jackson, TX 77566
October 1 3 , 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey

Ave., SE Washington, DC 20590 **Re: Exemption Request Under Section 333 of the FAA Modernization and**  **Reform Act of 2012 and Part 11 of**  **the Federal Aviation Regulations from Certain Provisions of 14 C.F.R.**


### Dear Sir, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Spectre Aerial Productions , LLC, (Spectre) hereby seek s an exemption from 14 C FR § § 91.7(a) , 91.119(c), 91.121 , 91.151(a)(1) , 91.405 (a); 407(a)(1); 409(a)(1)&(2); 417(a)&(b) , to allow commercial operations of small unmanned aerial system s ( sUAS).Page | 2 **Table of Contents**

**I. Petitioner**  **Contact Information II.**  **Background III.**  **FAR Relief Requested & Extent of Relief IV.**  **Granting Request i**  **n the**  **Public Interest V.**  **Safety in the**  **National Airspace System**  **VI. Summary for Publication**  **VII. Operating Description** 

 **Crew**  **Flight**  **Aircraft VIII.**  **Appendix A -**  **Flight Operations Manual**

 **Preparation for Flight**  **Pre -** **Flight Inspection**  **Flight Test**  **Flight and Post Flight**Page | 3

**I. Petitioner Contact Information:**  Herbert L Ross, Jr Spectre Aerial Productions, LLC 202 Teakwood St Lake Jackson, TX 77566 Email: HLRossJr@comcast.net Phone: 979
-480 - 7192 **II. Background**  

### Spectre seeks exemption of specific requirements of 14 CFR. Approval of the exemption will allow Spectre to collect aerial data for clients in various industries such as real estate, roofing, construction, agriculture, surface mining, pipelines, electrical transmission systems, and other industries. The safety and public benefits of using these UAs for data collection are signific ant. The UAs covered b y this petition are small battery powered craft, usuall y weighing much less than 55 lbs., are restricted to less than 400 feet above ground level and have a very small chance, when following the FAA requirements, of interacting with manned aircraft. The small UAs are also capable of performing tasks , such as inspection of electrical towers and petrochemical plant equipment, making it safer for the scaffold builders and inspectors by eliminating the need of scaffolds to make inspections. By eliminating the need for scaffolds, there is a large cost savings for the industry
. Spectre would like to participate in the upcoming drone invasion of cost savings, risk reduction and future breakthrough activities that are not even known today
. With this exemption, Spectre will be able to pursue the safe exploration of drone capabilities.
**III. FAR Relief Requested & Extent of Relief and Reasons**  

### 14 C.F.R. § 91.7(a) : Airworthy Condition Section 91.7(a) requires aircraft to be in airworthy condition. Relief is requested to achieve airworthy condition b y compliance with the operating procedures, checklists, and documents prescribed in this petition prior to every flight. 14 C.F.R. §91.119(c): Minimum Safe Altitudes Section 91.119 (c) establishes minimum safe altitudes for operation of civil aircraft over congested and uncongested areas. Spectre requests authority to operate at altitudes up to 400 feet AGL to achieve data collection at better resolution than is possible at higher altitudes and to remain clear of manned aircraft. While the lower altitude is closer to people, the small size, low weight and low speed of the UA presents significantly lower hazard to the public. Non participating people will remain an appropriate distance from the UAV while it is in operation.Page | 4



### 14 C.F.R. §91.121 : Altimeter Settings Section 91.121 requires each person operating an aircraft to maintain cruising altitude b y reference to an altimeter that is set to the an appropriate altimeter setting available before departure. Because the UA will be operating in reference to AGL, the reference altimeter setting will be the low est ground level in the area of planned flight and will be zero AGL. 14 C.F.R. §91.151(a)(1): Fuel Requirements for Flight in VFR Conditions Section 91.151(a)(1) requires all day VFR flights to operate with enough fuel to fly to first point of intended landing and then for at least an additional thirty minutes. Most of the UAs have less than 30 minutes of battery life and obviously

can’t meet this requirement. Spectre requests exemption from this rule on the condition that the UAV flight is restricted to a planned area with a margin of safety to all ow for battery depletion and safel y land. Some UA’s, such as the DJ I Inspire , have an automatic Return To Home feature that is activated on low battery
. 14 C.F.R. §91.405 (a); 407(a)(1); 409(a)(1)&(2); 417(a)&(b): Maintenance Inspections Since these sections onl y apply to aircraft with an airworthiness certific ate, Spectre requests relief from these Sections because airworthiness certificates are not required of sUAS. The PIC will inspect and ensure the UAV is airworthy before any fl ight
. **IV. Granting Request in**  **the Public Interest**  

### Public Benefits: The benefits to the public not only include safe operation in National Airspace listed in Section V but also ;
 Finding flood victims, lost children or hikers with visual and thermal imagery  Lower risk to workers when a UA can achieve the same inspection that would require scaffolding, cranes and safety harnesses for building s , radio and communication tower inspections and the cost would be significantly less.  Lower cost than using manned aircraft in collecting a time lapse aerial photograph of a construction site.  Enhance real estate sales with new techniques such as flyover video  Improve agriculture efficiency by detecting water imbalances in fields and diseases and stresses in the crops  Save energy

by locating heat losses in roofing with thermal imagery  Lower c osts to obtain data by UA , which is much less than by c onventional manned aircraft  Better quality

data since UA can obtain 10 times the resolution of conventional manned aircraft **V. Safety in**  **the National Airspace**  **System** 

### Safety : Provide Level of Safety Greater Than Existing Rule (Regarding Manned Aircraft)Page | 5



###  Smaller target. The significantly smaller size ( 3 f

oo t wingspan versus 30 f oot wingspan of popular Light Sport Aircraft (L SA) ) , and  Low er Momentum. The lower speed (max speed is usually les s than 60 mph) and the weight (less than 1/2 5 the weight of a Li ght Sport Aircraft) yi eld much smaller momentum if the UA were to strike an object, and  Low exposure to manned aircraft. a. Smaller area of operation based on range (wifi signal less than 1 mile and VLOS ) b. Maximum ceiling of 400 feet Above Ground Level, 100 feet below manned aircraft, and c. Less time in the air. Battery life of UA is commonly

less than 30 minutes.
**VI. Summary for Publication**  

### Spectre Aerial Productions, LLC, seeks exemption of specific requirements of 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b)
. Approval of the exemption will allow Spectre to collect aerial data for clients in various industries such as real estate, roofing, construction, agriculture, surface mining, pipelines and electrical transmission systems, and in other industries. **VII. Operating Description**  The goal of any flight is to acquire the aerial data needed by the client without adversely affecting the National Airspace System, public, and environment within the constraints of safe flight. The UA will be operated within rules established by FAA, the State of Texas, and local rules before any flight is considered. To accomplish this purpose Spectre will utilize the following condition s. **Crew**  Pilot In Command must have , at minimum, a sport pilot ’s license and a third class medical certificate, or a U.S. driver’s license
.  No PIC may operate the UA unless the PIC meets Spectre’s qualification criteria and demonstrates the ability to safely operate the UA. Spectre’s minimum experience to fly a commercial mission is 20 hours flight time or 150 flight cycles on UA rotorcraft and 5 hours flight time and 25 flight cycles in make and model.  Minimum flight crew is PIC and a visual observer (VO). The PIC may deem other crew essential to the safe operation of the UA to include camera operator, instructor, trainee, or other person necessary for the safe operation of the flight. **Flight**  Flight can only occur in Visual M eteorological C onditions (VMC) , a 3 mile visibility, maintaining a distance 500 feet below clouds and 2000 feet horizontally, in daytime only , and yield right of way to all manned aircraft  No flight higher than 400 feet Above Ground Level  No flight closer than 5 miles from airport denoted on a current FA 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.Page | 6

 No flight closer than 500 feet to non
-participating persons, vessels, vehicles and structures unless a barrier is in place and with permission of such persons
.  No flight over congested or densely populated area
.  The maximum speed is less than 5 0 mph, and the maximum weight is 55 pounds including payload.  Flights will be operated within visual line of sight (VLO S ) of the PIC and VO at all times.  PI C and VO will at all time s be able to communicate verbally
. **Aircraft** 

### Spectre Aerial Productions, LLC, plans to use the following sUAS:  

### DJI Inspire  

### DJIPhantom  

### DJI Spreading Wings  

### 3DRobotics Solo  

### 3DRobotics X8  

### 3DRobotics Aero  

### PrecisionHawk Lancaster  

### Altus Delta X4 Lite  

### Altus Delta X8  

### Altus Delta LRX  

### Yuneec T yphoon Q500  

### Yuneec Tornado H920  

### Talon 120 LE . Several of these are described below, and descriptions of others can be furnished if needed. **DJI Inspire** The DJI Inspire is a quadcopter capable of capturing 4K video and transmitting an HD video signal (up to 2km) to multiple devices. Equipped with retractable landing gear, it can capture an unobstructed 360 degree view fro m its camera. The built
- in camera has an integrated gimbal to maximize stability and weight efficiency while minimizing space. When no GPS signal is available, Vision Positioning technology provides hovering precision.  Model: T600  Weight: 2.9 kg (6.4 lbs)  Max climb: 5 m/s (16 fps)  Max speed: 22 m/s (49 mph)  Max wind speed resistance: 10 m/s (22 mph)  Max flight time: ~18 minutes  Operating Frequency: 5.725
- 5.825 GHz, 2.400 - 2.483 GHz  Battery: 4500 mAh LiPo 65 high voltage battery, and 5700 mAh  Features: Auto - Takeoff and Landing, Failsafe mode (Return To Home if remote control signal is lost more than 3 seconds), Low Battery Return Home mode, Dynamic Home Point mode, Intelligent Orientation Control, Flight Recorder.Page | 7

**DJI Phantom** The DJI Phantom Pro is a quadcopter capable of capturing 4K video and transmitting real time HD video signal to a device. When no GPS signal is available, Vision Positioning technology provides hovering precision.  Model: Phantom 3 Pro  Weight: 1.3 kg ( 2.9 lbs)  Max climb: 5 m/s (16 fps)  Max speed: 16 m/s ( 35 mph)  Max flight time: ~23 minutes  Operating Frequency: 2.400
- 2.483 GHz  Battery: 4480 mAh LiPo 45  Features: Auto - Takeoff, Failsafe mode (Return To Home if remote control signal is lost more than 3 seconds), Low Battery Return Home mode, Flight Recorder. 

### DJI Spreading Wings The DJI Spreading Wings is an octocopter with a large carrying capacity that can handle a DSLR camera. Retractable landing gear and low gimbal mounting enable a wide range of shooting angles and camera motions.  Model: S1000+  Weight: 4.4 kg ( 9.7 lbs)  Weight with Payload: 6.2 kg
- 11.0 kg (13.7

– 24 lbs)  Max climb: 6 m/s (19 fps)  Max speed: 16 m/s ( 35 mph)  Max flight time: ~18 minutes  Operating Frequency: 30 Hz - 450 Hz  Battery: 10,000

– 20,000 mAh LiPo 65 

### 3DRobotics Solo The 3DRobotics Solo is a quadcopter that can control a GoPro camera during flight.

 Model: Solo  Weight: 3.9 lbs with gimbal and GoPro camera  Range: 0.5 miles  Max Speed: 55 mph  Max Ascent: 10 m/s (32 fps)  Flight Time: 20 minutes with payload  Frequency: 2.4 GHz  Battery: 5200 mAh LiPo 

### 3DRobotics X8 The 3DRobotics X8 is a quadcopter with camera and controller designed to create high resolution visual spectrum aerial maps. It offers low flying and high accuracy mapping with a fully redundant propulsion system for increased reliability.Page | 8

 Model: X8
-M  Weight: 3.5 kg (7.7 lbs)  Range: 0.6 miles  Recommended Speed: 11 mph  Max wind speed: 25 mph  Flight time: 14 min  Frequency: 915 mHz or 433 mHz  Battery: 4S 10,000 mAh 10C LiPo  Payload capacity: 200 g (0.4 lbs)Page | 9 

## Appendix	A **Flight	Operations	Manual** The following steps are to be p erformed on every flight. **Preparation for flight** 1) Ensure firmware version is up to date 2) Ensure maintenance has been completed and aircraft is cleared to fly 3) Plan area of flight and ensure area is clear of obstacles and people 4) Obtain permission from land owner of area of flight 5) Before each flight complete a Pre -Flight Inspection 6) Set max height and radius limits on aircraft 7) Set home position at low est ground elevation in flight area 8) Perform Flight Test **Pre -** **Flight Inspection** (specifically DJI Inspire) 1) Remote controller, aircraft battery and mobile device are fully charged 2) Propellers are mounted correctly and firmly. 3) Micro
- SD card has been inserted 4) Gimbal is functioning normal ly 5) Motors can start and are functioning normal ly 6) DJIPilot app is connected to the aircraft **Flight Test** (specifically DJI Inspire) 1) Place the aircraft on open, flat ground with battery indicators facing toward you. 2) Power on the remote controller and the mobile device, then the Intelligent Flight Battery. 3) Launch the DJI Pilot App and enter the Camera page. 4) Wait until the Aircraft Indicator blinks green. This means the Home Point is re corded and it is safe to fly . If it flashes yellow, it means Home Point is not recorded, and you should not take off. 5) Push the throttl e up slowly or use Auto Take
- off to take off
. 6) Shoot photos and vi deos using the DJI Pilot app. 7) Land

– hover over a level surface and pull down on the throttle slowly to descend. 8) After landing, execute the CSC command or hold the throttle at its lowest position for 3 seconds or more until the motors stop. 9) Turn off the Intelligent Flight Battery first, followed by the Remote Controller. **Flight and Post Flight** 1) Perform flight following the UA’s Operation Manual 2) After landing, execute the CSC command or hold the throttle at its lowest position for 3 seconds or more until the motors stop. 3) Turn off the Intelligent Flight Battery first, followed by the Remote Controller. 4) Restore flight area to same condition as before the flight 5) Record flight time and maintenance needs in the UA’s logbook 6) Perform minor maintenance or send UA to manufacturer for repair