February 15, 2016

Jeff Rasco 22 Knight Ave Sequim WA

98382 360

-809

-0793 rasco@olypen.com

Federal Aviation Administration:

I, Jeff Rasco, am writing pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Jeff Rasco, an owner and operator of small unmanned aircraft, be exempted from the Fede ral Aviation Regulations (FAR) listed below that I may operate a small ultra light we ight unmanned aircraft system (UAS ) commercially in airspace regulated by the Federa l Aviation Administration (FAA) in accordance with FAA UAS Regulations & Policies. I currently hold a commercial, instrument fixed wing and commercial rotorcraft license.
The requested exemption would permit me, Jeff Rasco, to conduct commercial operations of the UAS meeting or exceeding the operational safety requirements set forth in Section 333. Commercial operation of the UAS equipped with a camera would be used for the following: Aerial photography and/or video for print publication, insurance, real estate, utility inspection , land surveying, engineering, television, public events, cinematography, news gathering, advertising , utility inspections , search and rescue, security, aerial mapping and training

. Traditional methods of aerial photography and video are not viable options for the average consumer as they are not cost effective and involve risks to everyone involved. A UAS operation is more affordable and safer for the community and better for the en vironment than airplanes or helicopters. A UAS does not carry flammable fuel, emit carbon dioxide or hold a pilot, crew or passengers. This proposed exemption would allow me operation of the UAS for the purpose of aerial photography and vi deo as a service to the public/business interests. They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, 11213 and 12645.UAS to be utilized will include the Quanum Nova , Cheerson CX

-20, DJI Phantom

2 and DJI Phantom 3

. Th ese UAS will be equipped with detachable camera and will be transported in proper storage. These UAS are selected because they have proven reliable flying capabilities managed by gyro stabilized flight, GPS aided navigation, a compass, bl inking LEDs and failsafe mode for returning home. This will act to further safety protocols exclusive to lightweight UAS specific to video and photography usage as I, Jeff Rasco, record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to assists with future protocol and safety regulations.
I am submitting a request for an exemptio n from the following regulations: 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.23(a) & (c) 14 C.F.R. 61.101(e) (4) & (5) 14 C.F.R. 61.113(a) 14 C.F.R. 61.315(a) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b)(2) 14 C.F.R. 91.119(c) 14 C.F.R. 91.121 14 C.F.R. 91.151(a)(1) 14 C.F.R. 91.405(a) 14 C.F.R. 91.407(a)(1) 14 C.F.R. 91.409(a)(1) & (2) 14 C.F.R. 9 1.417(a) & (b) **Specific section or sections of 14 CFR which I**  **seek relief and the reason I**  **seek relief:** 14 C.F.R. Part 21: Airworthiness Certificates I am requesting relief base on the given size , weight, speed and limited operating area associated wi th the UAS to be utilized

. A UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than conventional aircraft operating with an airworthiness certificate. 14 C.F. R. 45.23 (b) : Display of marks: general The UA does not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain words or phrases. Further, the two inch lettering is not practical to place on such a small aircraft with dimensio ns smaller than the minimal lettering requirement. An equivalent level of safety will be maintained by making the lettering as large as practical.14 CFR 61.23(a) & (c): Operations requiring a medical certificate

This regulation is intended for a pilot in command of an aircraft and not a UAS. An equivalent level of safety will be maintained by insuring the PIC has a valid driver’s license. 14 CFR 61.101(e) (4) & (5): Recreational pilot privileges and limitations. I request relief to the extent necessary to allow a PIC holding a recreational pilot certificate to conduct the proposed UAS flight operations for compensation or hire. An equivalent level of safety will be maintained because the PIC of the UAS will be proficient and abide by all rules specified in the requested exemption. 14 C.F.R. 61.113(a) : Private pilot privileges and limitations: Pilot in command I request relief to the extent necessary to allow a PIC holding a private pilot certificate to conduct the proposed UAS flight operations for compensation or hire. An equivalent level of safety will be maintained because the PIC of the UAS will be proficient and abide by all ru les specified in the requested exemption. 14 C.F.R 61.315(a) Privileges and limits of my sport pilot certificate I request relief to the extent necessary to allow a PIC holding a s port pilot certificate to conduct the proposed UAS flight operations for compensation or hire. An equivalent level of safety will be maintained because the PIC of the UAS will be proficient and abide by a ll rules specified in the requested exemption. 14 C.F.R 91.7 (a) : Civil aircraft airworthiness Currently there is no airworthiness certificate applicable for the UAS in question. The use of safety check lists to conduct inspections prior to each flight wil l provide an equivalent level of safety. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements I am requesting relief from this regulation because there is no pilot on board this aircraft to read a flight manual. G iven the size of the UAS , this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the operator. 14 C.F.R. 91.119(c): Minimum safe altitudes I will ensure that UAS do not ope rate any higher than 40 0 feet above ground level. I will not fly over congested areas. I will plan operations before hand, for proper flight safety, and proper height analysis as to avoid collisions. 14 C.F.R. 91.121: Altimeter settings The UAS is too small to accommodate an al timeter and there is no pilot onboard to read one. An equivalent lever of safety will be maintained by using GPS to determine altitude.14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The UAS that I will fly are powered by electricity, using lithium polymer batteries that currently have a flight limit of approximately no more than 20 minutes. Therefore, due to the limitations of the batteries, it is not possible to comply with this regulation

. Safety will be maintained by insuring that before each flight there is enough power for the UAS to conduct the flight and to operate after that for at least five minutes or greater if recommended by the manufacturer. 14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Relief is requested from these regulations because the UAS does not have an airworthiness certificate. Trained technicians will be utilized to perform maintenance or alterations

. P reflight inspections of the UAS before each flight as outli ned in the operating documents will be conducted and I wi ll also follow manufacturer recommendations from said operating docum ents to maintain safety

. **Public Interest** Aerial video and photography as an available service to the public allows for a l ess expensive method to capturing imagery than aircraft and helicopters. Aircraft and helicopters are expensive, create lots of noise , and are much more hazardous due to size and combustible fuel. **Summary** I am seeking exemption from the following rules: 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.23(a) & (c) 14 C.F.R. 61.101(e) (4) & (5) 14 C.F.R. 61.113(a) 14 C.F.R. 61.315(a) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b)(2) 14 C.F.R. 91.119(c) 14 C.F.R. 91.121 14 C.F.R. 91.151(a)(1) 14 C.F.R. 91.405(a) 14 C.F.R. 91.407(a)(1) 14 C.F.R. 91.409(a)(1) & (2) 14 C.F.R. 91.417(a) & (b)
With the exemptions of the mentioned rules I, Jeff Rasco, will be seeki ng to make my drone photography and video services available to the public. I will operate the UAS in a safe manor, including but are not limited to:● UAS weighing less than 55 lbs. ● Not operating at night ● Flying below 400 feet AGL ● Conducting a pre-flight inspection prior to each flight ● Keeping UAS in visual line of sight at all times when in operation ● Using an observer to assist ● Remain ing well clear of and not interfering with manned aircraft operations, and avoid ing other aircraft and obstacles at all times ● Not intentionally fly over unprotected persons or moving vehicles ● Contacting the airport and control tower before flyi ng within 5 miles of an airport ● Not flying in adverse weather conditions such as high winds or reduced visibility ● Not flying under the influence of alcohol or drugs ● Ensuring the operating environment is safe ● Not flying over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, etc. ● Checking and following all local laws and ordinances before flying over private property ● Not conducting survei llance or photograph of persons in areas where there is an expectation of privacy without the individual's permission.

Thank you for your consideration. Respectfully, Jeff Rasco 22 Knight Ave Sequim WA

98382 360

-809

-0793 rasco@olypen.com