PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 1

December 15, 2015

Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department of Transportation, Docket Operation West Building Ground Floor Room w

- 12

- 140
1200 New Jerse y Ave, SE Washington, DC 20590



## Petition for Exemption

RE: Petition of Manny Rodriguez for an Exemption under Section 333 of the FAA
Modernization and Reform Act of 2012 and from certain rules of 14 C.F.R.

Dear Sir or Madam:

The followin g is a Petition for Exemption relating to Section 333 of the FAA Modernization and Reform Act of 2012. Specifically, this Petition for exemption is filed by DMZ Marketing, LLC., on behalf of Manny Rodriguez for exemption from certain rules of 14 C.F.R. Manny Rodriguez
requests Exemption in a n effort to be granted permission to operate small Unmanned Aircraft Systems (“sUAS”) commercially in the United States of America. These operations would be subject to the current rules and regulations , not stated herein as rules requested for exemption under Section 333, under the jurisdiction of the Department of Transportation and the Federal
Aviation Administration

. Additionally , all operations will adhere to str ict safety rules enforced by Manny Rodriguez
within his company

. These safety rules will be modeled after recommendations made by the FAA and community

- based organizations such as the Acade my of Model Aeronautics. Specific conditions relating to the safe operations of sUAS by Manny Rodriguez will be covered in more detail in the documentation to come, however

, basic flight safety parameters often cited by

orga nizations such as the Academy of Model Aeronautics will be closely followed, such as operations at low altitudes and adequate distances away from airports, heliports, and approach
areas to name a few. Petitioner Name: Manny Rodriguez Petitioner Contact: Manny Rodriguez Petitioner Phone Number: 520

- 465

- 4357 Petitioner Email Address: 1@EZONE23.COM Petitioner Address: 3825 East Mainsail Blvd. Tucson, AZ 85739

Document Preparer : DMZ Marketing, LLC. Contact Person: Zach Fiene Phone Number: 608

- 370

- 2858 Email Address: dmzaerial@gmail.com Website: www.dmzaerial.com Address : 1501 Parkview Court Prairie du Sac, WI 53578 USAPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 2



### As was established in Huerta v. Pirker

, an aircraft is , “any” “device” that is “used for flight.” 1 

### Clearly this broad definition encompasses the types of sUAS the petitioner, Manny Rodriguez

, plans on flying commercially within the United States of America and as such, are governed by the rules of 14 C.F.R. Due to this, in the following Petition for Exemption and associated documentation, Manny Rodriguez will e stablish clear reasoning as to why his particular commercial sUAS flights should be granted exemption and why his business should be exempt from certain parameters of 14 C.F.R.

A s has been established by the FAA ov er the last year, sUAS pilots are allow ed to petition for exemption from certain aircraft rules that may be inapplicable to sUAS craft or that may place an undue burden on a peti ti oner looking to turn their sUAS hobb y into a commercial business. Manny Rodriguez w ould like to request exemption from certain parameters contained in 14 C.F.R. The specific rules for which Manny Rodriguez requests exemption will be covered in further detail in the documentation to come, but, in summary, Manny Rodriguez looks to be exempt from the types of rules that may limit or otherwise prevent his intent of operating sUAS commercially within the United States.

Furthermore, t hese commercial operations would only be conducted after a granted Section 333 Exemption and within the outlined conditions below or that may be otherwise highlighted by the Federal Aviation Administration in their Exemption Approval Letter

. With the approval of this exemption, Manny Rodriguez will be allow ed to commercially operate
his sUAS within the United States of America. Specifically, Manny Rodriguez will be allowed to fly commercially with the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. Furthermore, Manny Rodriguez will be opera ting his sUAS in furtherance of various applications within the following i ndustries; Agriculture

, Cinematography

, Infrastructure

, Insurance

, Land Inspection

, Real Estate

, and Search and Rescue

. Details of these flight crafts; their manuals, safety parameters, operational checklists and more, along with these sUAS flight applications, will be expanded upon in more detail b elow.

In addition to Manny Rodriguez ’s Petition for Exemption pertaining to the use of the
aforementioned aircraft and use

- cases, the granting of this Petition will also allow for th e commercial operations of sUAS in Clas s G Airspace, below 400 feet Above Ground Level (“AGL”) , nationwide, or as otherw ise granted in a Certificate of Authorization (“COA”). To start, Manny Rodriguez will adhere to the blanket Certificate of Authorization that is granted to each entity receiving an Exemption Number. This COA currently allows for flights nationwide, in Class G Airspace, below 200 feet AGL. 2 

### Further flight areas sought by Manny Rodriguez will be applied for through the FAA’s COA Portal. Additionally, with the potential hazards and
obstacles associated with low

- altitude flight

, Manny Rodriguez will adhere to the Visual Flight Rule (“VFR”) minimums which ap ply to this airspace. Further details on these operational
minimums will be discussed in the documentation to come.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 3



### The Petitio n for Exemption below provides details relating to the proposed applications of commercial sUAS use by Manny Rodriguez

. Specifically, Manny Rodriguez seeks exemption in an effort to conduct commercial operations within the following industries; Agriculture

, Cinematography

, Infrastructure

, Insurance

, Land Inspection

, Real Estate

, and Search and

Rescue

.
In addition to the v ariety of Industry ap plications highlighted above, this Petition for Exemption will also cover details on various methods of operation and sensor/imagery types for the various applications. Specifically, Manny Rodriguez will incorporate a v ariety of sensor payloads on his sUAS in an effort to capture necessary imagery or data types for each specific application or use

- case. Examples of the payload technologies used on the sUAS include, but are not limited to; Visible Light Spectrum Imagery, Near Infrared ( “ NIR ” ) Imagery, Thermal Infrared Imagery, LIDAR, Se nsor Technologies , GPS Guidance, Photogrammetry, Semi

Autonomous and Autonomous Flight Controllers (For safety), Object Avoidance Systems, and more. With the data collected from these vari ous sensor payloads, Manny Rodriguez will be able to provide high quality data for representatives from the below

- highlighted industries.

 Agriculture: High quality, actionable data can be utilized by farmers and their partner agronomists, crop consultants, field techs, and interns alike, to support their drive for higher yields and more efficient and effective farming practices.

 Cinematography: High resolution video can provide a new perspective of a product for potential buyers. By providing an aerial shot to the director of a commercial shoot, t hese video marketers can more effectively represent a company’s product, which in turn returns value to that commercial customer and provides for a stronger economy through increased demand for products
and services.

 Infrastructure: High quality, high resolution imagery, 3D modeling, and the like, provided to the Infrastructure industry can create a better Infrastructure Industry as a whole. Not only will the data they receive from an aerial inspection be actionable, but the method by which the data is collected (via sUAS) is much safer than the alternative in many Infrastruct ure Industries. Consider cell towers as an example. Rather than having someone repel down the tower to take pictures, exposing themselves to a variety of hazards (falls, electrocution, falling objects, etc.), a sUAS can provide the same or better imagery in a fraction of the time with a safer method of image capture.

 Insurance: High quality, high resolution imagery, coupled with advanced identification and measurement software, can help turn aerial data collected by a sUAS into actionable information for Insurance Agents and Adjusters alike. With an aerial map of a field for example, advanced software can identify destroyed areas of the field, measure the acres lost, and in turn provide an accurate, automated, non

- partisan assessment of crop loss.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 4 

###  Land Inspection: High quality, high resolution imagery and 3D modeling can help land assessors, government agencies, surveyors, insurers, and the like utilize
aerial data to ensure confidence in their operations and efficiency in their practices.

 Real Estate: High quality, high resolution imagery and aerial cinematography can provid e a new perspective for an interested home buyer which in turn allows for another marketing piece for land developers and real estate agents to move properties and thus create a stronger housing market.

 Search and Rescue: High quality, high resolution imagery and aerial video can provide an incredible vantage point from which search and rescue teams can more effectively scope out an area. Furthermore, with the abi lity to stitch still images and georeference data, Search and Rescue teams can more effectively map the areas they have already search ed and more efficently direct their
resources to lesser searched areas.

The applications highlighted in this petition obviously p rovide high quality data to a variety of interested parties in vari ous industries. However, sUAS have mor e to provide than just interesting pictures and efficient operations. There is also the enhanced safety sUAS provide not only for the operators of these systems, but also, the people around them, communities as a whole, and the National Airspace System (“ NAS”).

Within this Petition for Exemption you will find that the applications highlighted above along with the aircraft systems utilized by Manny Rodriguez , satisfy the conditions highlighted by the
Federal Aviation Administ ration as requirements for a successful Section 333 Exemption
Petition

. 3 

### Specifically, the sUAS operating in furtherance of the industry applications above should;

1. Provide a benefit to the public as a whole, and;
2. Not adversely affect safety.

To answer these requirements this Petition for Exemption will highlight the public benefits provided by the proposed sUAS operations as well as show the positive affect these operations will have on safety. Specifically, it will be shown that the commercial sUAS flights proposed in this Petition further the public interest by satisfying what is sometimes referred to as the 3D’s or 4D’s of Unmanned Aerial Vehicle (“UAV”) Intervention

. 4 

### Basica lly, the “D” list provides a description of situations in which an unmanned vehicle should be used in place of a manned aircraft, more clearly, those situations in which an aerial operation is going to be; Dull, Dirty, Dangerous, or Deep

. 5 

### This list is often associated with early military applications utilizing UAV’s. The UK Ministry of Defense for example still uses this list in determining the role of Unmanned Aircraft, highlighting the importance of Unmanned Systems in times where the operation is ; 5PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 5 

###  Dull

- flights require persistence or repetition.  Dangerous

- flights carry a high degree of risk.  Dirty

- flights must be carried out in hazardous environments, or;  Deep

- flights are beyond the range of manned platforms.

In addition to the justification that will be provided in detail in the pages to come relating to the 4 D’s of UAV Intervention and safety attributes of the sUAS Operations proposed in this Petition for Exemption, it is also important to quickly consider the aircraft types utilized by Manny Rodriguez

.

As mentioned above, Manny Rodriguez seeks exemption for the utilization of the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. All of these aircraft ar e small Unmanned Aircraft Systems and are battery

- powered. Operations conducted by Manny Rodriguez with
these sUAS will adhere to the guidelines set forth by the Federal Aviation Administration and Community

- Based Organizations such as the Academy of Model Aeronautics (“AMA”). Through the adherence of these guidelines Manny Rodriguez will commercially operat e his sUAS with an equivalent level of safety, if not superior level of safety, as outlined by the Federal Aviation Administration’s Section 333 Exemption Guidelines.

Furthermore, the commercial sUAS operations being proposed by Manny Rodriguez in this Petition for Exemption would produce far safer methods of data capture than currently

- used collection methods in which manned aircraft are used. Consider that manned aircraft weigh thousands of pounds, are made of metal, are powered by a combus tion engine, carry flammable fuel, and are carrying people. Plus, with the type of data

- capture proposed in this Petition, a manned aircraft would ha ve to operate in high

- risk situations, including, in close proximity to the ground where the risk of an accident is highest and the risk to people and property on the ground is the greatest. Contrasting the two aircraft types, it is clear that a plastic, battery powered, unmanned vehicle operating at low altitudes, would be much safer than a multi

- thousand

- pound metal aircraft, powered by a combustion engine, and carrying a person at low altitudes.

This fact is furt her bolstered by the operational and a ircraft

- specific parameters giv en by the FAA when deciding whether or not to grant Section 333 Exemptions

. 6 

### These directives include ;

1. The size of the aircraft
2. The weight of the aircraft
3. The speed of the aircraft
4. The operational capability of the aircraft
5. The aircraft operation’s proximity to airports
6. The aircraft operation’s proximity to populated areas , and;
7. The aircraft operation’s adherence to Visual Line of Sight Rules

As highlighted above, it is clear that this Petition for Exemption and both the aircraft types and applications state d herein, strictly adhere to the operational and aircraft

- specific parametersPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 6



### highlighted by the FAA for a successful Exemption Petition and thus, support the granting of this Exempti on. A summary of the reasoning behind this statement can be found below as;

1. All proposed sUAS are Small
2. All proposed sUAS weigh below 55 lbs.
3. All proposed sUAS travel at less than 100 mph (87 Knots)
4. All proposed sUAS are capable flight systems and have b een granted Exemptions previously
5. All proposed operations will take place at least 5 miles from an Airport
6. All proposed operations will take place in unpopulated area s (U nless prior approval is given {See Condition #34 [“ Proposed Conditions of the Exemption ”] below})
7. All proposed operations will adhere to the Visual Line of Sight Rules

By adhering to t he parameters published by the FAA and by promoting the public good through the various Industry applications to be highlighted below, this Pe tition for Exemption on behalf of Manny Rodriguez s trongly support s approval

.

We kindly ask for your consideration of this Petition for Exemption. Please see the table of contents below for all our documentation and for assistance in reviewing this Petition. Thank you for your efforts in reviewing this document and we look forward to your response. If you have any questions while reviewing this document please do not hesitate to ask. You can contact the Preparer of this document for all questions relating to this petition and they can be
reached at 1

- 608

- 370

- 2858 or by email at dmzaerial@gmail.com . Further contact information can be found at th e top of this Petition or on the following website s; www.dronefly.com or www.dmzaerial.com . Once again thank you for your efforts in reviewing this Petition for Exemption and we look forward to your reply.

Best Regards,

DMZ Marketing, LLC. (DMZ Aerial)PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 7



## Contact Information

Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.com

Petitioner:

Manny Rodrigu ez 3825 East Mainsail Blvd. Tucson, AZ 85739 Manny Rodriguez
520

- 465

- 4357 1@EZONE23.COM



## Disclosure

The Petitioner for this exemption is Manny Rodriguez

, a UAV enthusiast who is seeking an exemption under Section 333 for himself in an effort to provide commercial UAV services to vario us customer groups moving forward. Manny Rodriguez purchased document prepar ation services through Dronefly

Inc. for the purpose of petitioning th e FAA to be allowed to fly his s mall Unmanned Aircraft Systems commercially within the United States. Dronefly Inc., contracts DMZ Marketing, LLC. also known as DMZ Aerial, to help formulate these documents and work with the customer to help promote safe flying practices and appropriate operations. This is done through question naires, phone conversations, document preparation, training module creation, and more. If you have any questions relating to the Petitioner, Dronefly, Inc. or DMZ Marketing, LLC. (“DMZ Aerial”), please do not hesitate to contact us using the contact infor mation provided above.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 8



## Table of Contents

Petition for Exemption

................................ ................................ ................................ ............................ 1

Contact Information

................................ ................................ ................................ ................................ 7

Disclosure

................................ ................................ ................................ ................................ ................ 7
The Applicant

................................ ................................ ................................ ................................ ........ 11
Commitment to Safety

................................ ................................ ................................ ...................... 11
Experience and Expertise

................................ ................................ ................................ ................... 12

Privacy

................................ ................................ ................................ ................................ ............... 12
Publishable Summary

................................ ................................ ................................ ............................ 12

Petitioner’s Contact Information

................................ ................................ ................................ ........... 14
Proposed sUAS Operati ons

................................ ................................ ................................ .................... 14
Small Unmanned Aircraft Systems

................................ ................................ ................................ ..... 14

DJI Phantom 3 Professional

................................ ................................ ................................ ............ 15

DJI Inspire 1

................................ ................................ ................................ ................................ ... 15

DJI Matrice 100

................................ ................................ ................................ .............................. 16

Unmanned Flight Crew

................................ ................................ ................................ ...................... 16
Unmanned Flight Conditions

................................ ................................ ................................ .............. 17
Unmanned Flight Operations

................................ ................................ ................................ ............. 18
Aircraft and Equivalent Level of Safety

................................ ................................ ................................ ... 18
National Security

................................ ................................ ................................ ................................ ... 18
Proposed Conditions of the Exemption

................................ ................................ ................................ .. 19
Exemptions Requested & Applicable Conditions/Reasoning

................................ ................................ ... 25
14 C.F.R 21(h): Airworthiness Certificates

................................ ................................ .......................... 25

14 C.F.R. 27: Airworthiness Standards

- Normal Category Rotorcraft

................................ .................. 25
14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

................................ ............... 25
14 C.F.R. 43.11: Dispositions of Records for In spections

................................ ................................ ..... 26
14 C.F.R. 45.11: Making of Products

................................ ................................ ................................ ... 26
14 C.F.R. 45.23(b): Display of Marks; General

................................ ................................ ..................... 26
14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft

................................ ................................ .......... 27

14 C.F.R. 45.29: Size of Marks

................................ ................................ ................................ ............ 27PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 9

14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations

................................ .......... 27
14 C.F.R. 61.23(a) and (c): Medical Certificates

– Requirements and Duration

................................ .... 28
14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

................................ ......... 29
14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command

.......................... 30
14 C.F.R. 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

................................ ................... 30
14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

................................ ................................ ..................... 34
14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual

................................ ................................ ................. 34
14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

................................ ................................ ............... 35
14 C.F.R. 91.103: Preflight Action

................................ ................................ ................................ ....... 35
14 C.F.R. 91.105: Flight Crewmembers at Stations

................................ ................................ ............. 36
14 C.F.R. 91.109: Flight Instruction

................................ ................................ ................................ .... 36
14 C.F.R. 91.113(b): Right

- of

- Way Rules

................................ ................................ ............................. 38

14 C.F.R. 91.119: Minimum Safe Altitudes

................................ ................................ ......................... 38

14 C.F.R. 91. 121: Altimeter Settings

................................ ................................ ................................ ... 39
14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

................................ ...................... 41
14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

................................ ..................... 41
14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use

................................ ..... 42

14 C.F.R. 91.403: General

................................ ................................ ................................ ................... 43
14 C.F.R. 91.405(a): Mainte nance Required

................................ ................................ ....................... 44
14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

................................ .................... 44
14 C.F.R. 409(a)(1) and (2): Inspections

................................ ................................ .............................. 45
14 C.F.R. 91.417(a) and (b): Maintenance Records

................................ ................................ ............. 45

Priva cy

................................ ................................ ................................ ................................ .................. 46
Public Interest and Safety

................................ ................................ ................................ ...................... 47
Agriculture

................................ ................................ ................................ ................................ ..... 48
Cinematography

................................ ................................ ................................ ............................ 52

Infrastructure

................................ ................................ ................................ ................................ 53

Insurance

................................ ................................ ................................ ................................ ....... 56
Land Inspection

................................ ................................ ................................ ............................. 58

Real Esta te

................................ ................................ ................................ ................................ ..... 60

Search and Rescue

................................ ................................ ................................ ......................... 62
Regulations Requested for Exemption

................................ ................................ ................................ ... 63
Appendix 1: Regul ations Requested for Exemption

– List

................................ ................................ ... 64PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 10

Exhibit List

................................ ................................ ................................ ................................ ............. 64
Exhibit 1: Manny Rodriguez Operations Manual

................................ ................................ ................ 64
Exhibit 2: Manny Rodriguez Logbook Example

................................ ................................ ................... 64

Exhibit 3: Manny Rodriguez Visual Observer Training Procedures & Guide

................................ ......... 64
Visual Observer Training Procedures

................................ ................................ .............................. 64
Visual Observer Training Guide

................................ ................................ ................................ ...... 65
Exhibit 4: Manny Rodriguez Pilot In Command Training Guide

................................ ........................... 65
Pilot In Command Training Procedures

................................ ................................ .......................... 65

Pilot in Command Training Guide

................................ ................................ ................................ ... 65

Exhibit 5: DJI Phantom 3 Professional

................................ ................................ ................................ 65

Exhibit 6: DJI Phantom 3 Professional User Manual

................................ ................................ ............ 65

Exhibit 7: DJI Phantom 3 Professional Quick Start Guide

................................ ................................ .... 65

Exhibit 8: DJI Phantom 3 Professional Features

................................ ................................ .................. 65
Exhibit 9: DJI Phantom 3 Professional Specifications

................................ ................................ .......... 66
Exhibit 10: DJI Phantom 3 Professional Flight Controller System

................................ ........................ 66

Exhibit 11: DJI Phantom 3 Professional Smart Battery Manual

................................ ........................... 66
Exhibit 12: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

................. 66
Exhibit 13: DJI Inspire 1

................................ ................................ ................................ ...................... 66
Exhibit 14: DJI Inspire 1 User Manual

................................ ................................ ................................ . 66
Exhibit 15: DJI Inspire 1 Quick Start Guide

................................ ................................ .......................... 66
Exhibit 16: DJI Inspire 1 Features

................................ ................................ ................................ ....... 66
Exhibit 17: DJI Inspire 1 Specifications

................................ ................................ ................................ 67

Exhibit 18: D JI Inspire 1 Flight Controller System

................................ ................................ ................ 67
Exhibit 19: DJI Inspire 1 Smart Battery Manual

................................ ................................ ................... 67

Exhibit 20: DJI Matrice 100

................................ ................................ ................................ ................ 67

Exhibit 2 1: DJI Matrice 100 User Manual

................................ ................................ ............................ 67

Exhibit 22: DJI Matrice 100 Features

................................ ................................ ................................ .. 67
Exhibit 23: DJI Matrice 100 Specifications

................................ ................................ .......................... 67

Exhibit 24: D JI Matrice 100 Smart Battery Manual

................................ ................................ ............. 68

References

................................ ................................ ................................ ................................ ............ 68
Exemption References

................................ ................................ ................................ ........................... 69PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 11



## The Applicant

The Applicant seeking this Exemption is Manny Rodriguez , headquartered at;

3825 East Mainsail Blvd. Tucson, AZ 85739

Mr. Manny Rodriguez is a business owner from Tucson, AZ. Mr. Rodriguez intends to be granted exemption under Section 333 of the FAA Modernization and Reform Act of 2012 in an effort to provide commercial UAV services to customers in various industry marke tspaces. Mr. Rodriguez has been doing videography and photography for over 28 years and utilizes visual media frequently in his current business marketing and promotion. Additionally, Mr. Rodriguez owns a hobbyist UAV and has utilized it in the past for hobby purposes. Through this use Mr. Rodriguez has seen the quality of the imagery captured by his UAV system and believes there is a commercial market not only for the imagery he captures but also for the services of capturing imagery. For this reason M r. Rodriguez is filing this Petition for Exemption under Section 333 in an effort to provide commercial UAV services utilizing his current UAV aircraft.

Furthermore, Mr. Rodriguez is also a member of United Companies Netw ork, LLC., which is primarily a marketing firm with an established network of independent business owners of small and large companies, that provide products and services for personal and business use. As a member of this organization, Mr. Rodriguez is continually meeting new people and developing new relationships with businesses owners from various industries. It is the focus of this organization to empower the group of companies by leveraging unique contacts and referrals between each of the individual businesses involved. This type of environment is obviously one in which referrals from various industries are possible and it is for this rea son that Mr. Rodriguez seeks an exemption under Section 333 for a variety of applications and uses cases which will be expanded upon further belo w.



### Commitment to Safety

Mr. Rodriguez is committed to operating within the National Airspace System safely and legally. It is for this reason that he has filed this Petition for Exemption in an effort to make his actions known and to be sure he is operating within the national airspace safely. Additionally, Mr. Rodriguez's intent to obtain a licensed pilot for all Pilot In Command duties (which will be disseminated below) shows his commitment to safety. By employing a licensed Pilot In Command, Mr. Rodriguez will ensure that his current UAV system is operated in a professional and safe manner.

Furthermore, it should also be noted that Mr. Rodriguez has owned a business of his own since 1989 that has speci alized in carpentry, manufacturing, and installation work. Although this business isn't necessarily tied to Mr. Rodriguez's future UAV work, his ownership of this manufacturing business for almost 30 years points to Mr. Rodriguez's compliance with various industry safety standards. Much in the same way, Mr. Rodriguez intends to employ various safety measures in his UAV business as well, which you will see in the Conditions of the Exemption below. By following these conditions Mr. Rodriguez will be in lin e with current accepted practices based on previously granted petitions forPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 12

exemption for UAV Service Businesses. For this reason, the following petition wi ll strongly support the approval of Mr. Rodriguez's petition.



### Experience and Expertise

Mr. Rodriguez has been doing videography and photography for over 28 years. He has taken real estate photos for publications and online use and has even served as a superintendent for housing
construction. Mr. R odriguez currently owns Manny's Organization Station, which has been in business since 1989 and provides high quality cabinetry. As the owner and operator of this business Mr. Rodriguez has produced much of the marketing materials and promotional videos f or the company as the business uses visual media heavily in its marketing strategies. The use of v ideo in his marketing has drawn Mr. Rodriguez to UAV systems and their potential to provide high quality imagery not only to his
business but also to clients ' businesses. It is for this reason that Mr. Rodriguez seeks exemption under Section 333. In addition, Mr. Rodriguez also grew up agriculture, which has given him background knowledge in the industry and positions him nicely to gain future business in th is space.



### Privacy

Privacy is important in any business, but especially one in which imagery is captured. For this reason, Mr. Rodriguez will use commonly accepted practices in order to secure his imagery. A few of the practices h e will put into action include; obtaining proper permissions, notifying authorities of any pending flights that may cause call

- ins, keeping data on a secure computer system, and the like. Furthermore, he will also seek what is required by law to remain co mpliant and secure in terms of data/imagery privacy.



## Publishable Summary

DMZ Marketing, LLC. files this petition for exemption on behalf of Manny Rodriguez

, a UAV enthusiast who is seeking an exemption under Section 333 for himself in an effort to provide commercial UAV services to various customer groups moving forward. Manny Rodriguez is seeking exemption from certain parameters of 14 C.F.R. in orde r to commercially operate sUAS within the United States in the following industries; Agriculture

, Cinematography

, Infrastructure

, Insurance

, Land Inspection

, Real

Estate

, an d Search and Rescue

. Specifically, Manny Rodriguez requests exem ption from the following Federal Aviation Administration rules;

1. 14 C.F.R 21(h): Airworthiness Certificates

2. 14 C.F.R. 27: Airworthiness Standards

- Normal Category RotorcraftPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 13

3. 14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

4. 14 C.F.R. 43.11 : Dispositions of Records for Inspections

5. 14 C.F.R. 45.11: Making of Products
6. 14 C.F.R. 45.23(b): Display of Marks; General

7. 14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft
8. 14 C.F.R. 45.29: Size of Marks

9. 14 CFR 61.3: Requirement for Certificates, Ratings, and Authorizations
10. 14 CFR §§ 61.23(a) and (c): Medical Certificates

– Requirements and Duration

11. 14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

12. 14 CFR 61.113(a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command

13. 14 C.F.R. 61.315(a): Privileges and Limits of Sport Pilot’s License

14. 14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

15. 14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual
16. 14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

17. 14 C.F.R. 91.103: Preflight Action
18. 14 C.F.R. 91.105: Flight Crewmembers at Stations
19. 14 C.F.R. 91.109: Flight Instruction
20. 14 C.F.R. 91.113(b): Right

- of

- Way Rules

21. 14 C.F.R. 91.119: Minimum Safe Altitudes
22. 14 C.F.R. 91.121: Altimeter Settings
23. 14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions
24. 14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

25. 14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use
26. 14 C.F.R. 91.403: General
27. 14 C.F.R. 91.405(a): Maintenance Required

28. 14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

29. 14 C.F.R. 409(a)(1) and (2): Inspections
30. 14 C.F.R. 91.417(a) and (b): Maintenance Records

The approval of this Petition for Exemption would allow for the commercial operation of small Unmanned Aircraft Systems by Manny Rodriguez

. These commercial operations would strictly adhere to all Federal Aviation Administration rules and regulations not stated herein as rules requested for exemption. The commercial operations flown by Manny Rodriguez , if this Petition were granted, would be flown utilizing one of the following aircraft platforms; the DJI Phantom 3 Professional

, DJI In spire 1

, and DJI Matrice 100

. Additionally, all the industry applications highlighted above would include one or more of the unmanned
aircraft noted above flying no more than 400 feet Above Ground Level (“AGL”) o r in airspace otherwise

spec ified in a granted C ertificate of Authorization (“COA”).

Furthermore, this Petition for Exemption should be granted to Manny Rodriguez because th e operation
of the listed sUAS above will provide for commercial operations while maintaining a n equivalent level of safety as would be provided by the above

- listed rules. Additionally, as will be highlighted below, the small Unmanned Aircraft utilized by Manny Rodriguez will provide methods of aerial data collection far safer
than the alternative of manned aircraft collection of the same data sets. Low altitude data

- collectionPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 14

flights, in close proximity to people and property, are far safer when accomplished using a battery

pow ered sUAS weighing less than 10 lbs., t han with a combustion

- engine

- powered, multi

- thousand pound, manned aircraft, with flammable fuel onboard.

Considering the seve n factors highlighted by the FAA as parameters for successful Section 333 Exemption Petitions, including; Size, Weight, Speed, O perational Capability, Proximity to Airports, Proximity to Populated Areas, and Operations within Visual Line of Sight

, 6 this Petition supports the Petitioner’s

re quest for exemption relating to each operational and aircraft

- specific parameter . Specifically, the aircraft utilized by Manny Rodriguez are in the small

- size category as they are below the 55 lbs. weight class, they travel at less than 100 mph, they are proven flight platform s based on previously granted petitions, all operations will be conducted at least 5 miles from an airport and over unpopulated areas (unless otherwise granted permis sion by the FAA in a granted Certificate of Authorizatio n), and all flights
will be conduc ted within Visual Line of Sight.

In addition, the data collectio n flights provided by the sUAS highlighted in this Petition will promote safer operations for professional service providers in the aforementioned industries.



## Petitioner’s Contact Information

Petitioner:

Manny Rodriguez 3825 East Mainsail Blvd. Tucson, AZ 85739
520

- 465

- 4357 1@EZONE23.COM



## Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.com



## Proposed sUAS Operations

Small Unmanned Aircraft Systems

This Petition for Exemption under Section 333 will permit the Petitioner the right to operate the DJI Phantom 3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. Further operatin g characteristics,PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 15

specifications, and other important craft

- specific information on the DJI Phantom 3 Professional

, DJI Inspire 1

, a nd DJI Matrice 100 are covered in detail startin g with Exhibit 5 . Each of these documents are publically circulated and have been previousl y vetted by the FAA in previously granted Petitions for Exemption under Sect ion 333. In the aircraft summaries below , please see the references to previously
grant ed petitions for the use of each specific aircraft type in commercial operations within the United
States

.


### DJI Phantom 3 Professional

The requested exemption will permit the Petitioner the right to use the DJI Phantom 3 Professional Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines, ATO

- Issued COA’s, and the like. The DJI Phantom 3 Professional has a weight of 1280 grams including propellers and batteries. Furthermore, this quadcopter is capable of a max flight speed of 16 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Pos ition  S imultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Phantom 3 Professional

- Specific Exhibits below for more information on the DJI Phantom 3 Professional craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting
documents for the commercial use of the DJI Phantom 3 Professional in the following listed Exem ption ;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587A



### DJI Inspire 1

The requested exemption will permit the Petitioner the right to use the DJI Inspire 1 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Inspire 1 has a weight of 2935 grams including the battery payload. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in ev ery lateral direction

For easy reviewing, please see the Inspire

- Specific Exhibits below for more information on the DJI Inspire 1 craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review ofPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 16

these exhibits an d granting of Petitions using these supporting documents for the commercial use of the DJI Inspire 1 in the following listed Exemptions;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Exemption Number 11587/11587A  Phillip Stiles

– GPS Development, LLC dba SkyViewHD

– Exemption Number 11399/11399A



### DJI Matrice 100

The requested exemption will permit the Petitioner the right to use the DJI Matrice 100 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,

ATO

- Issued COA’s, and the like. The DJI Matrice 100 has a maximum take

- off weight of 3400 grams including technical payloads and batteries. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Matrice 100

- Specific Exhibits below for more information on the DJI Matrice 100 craft, its specifications, abi lities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Matrice 100 in the following listed Exemptions;

 Dan Pham

– Alert5 Inte rnational, LLC.

– Exemption Number 11814



### Unmanned Flight Crew

The unmanned flight crew ope rating Manny Rodriguez flight crafts for purposes of commercial operations within the United States under this proposed Exe mption will consist of a Pilot I n Command (“ PIC”) and a Visual Observer (“VO”).

Adhering to current FAA guidelines and precedent established in previously granted Section 333 Exemptions, the PIC will have, at minimum, a Recreational or Sport Pilot’s License and a Third Class
Medical Certificate or a valid U.S. Driver’s License

. 7 Additionally, both the PIC and VO will be trained in the operation of sUAS prior to commercial operations. Furthermore, any new information surrounding the aircraft’s efficient, effective, or safe operations, will be disseminated by Manny Rodriguez to both
the PIC and VO to ensure continued safe f lights.

On top of the general sUAS training, the PIC will also have completed, at a minimum, 25 hours of sUAS flight training with the specific sUAS craft they are using for their commercial operation and will be required to receive annual continued educat io n and training moving forward. A specific PIC Training Presentation is contained in the exhibits below and will accompany this Petition for Exemption.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 17

The Visual Observer will also have completed specific trai ning relating to their duties during an

unma nned flight. The training procedures that will be used to educate VO’s are contained in Exhibits 1
& 3 below.



### Unmanned Flight Conditions

As has been described above, the sUAS use proposed by the Petitioner in this Petition for Exemption
under Section 333 revolves around the following industries; Agriculture

, Cinematography

, Infrastructure

, Insuranc e , Land Inspection

, Real Estate

, and Search and Rescue

. Each of these industry applications will
be described in further detail below under the “ Unmanned Flight Operations ” Title.

Moving on from the specific use cases, it should also be noted that all commercial sUAS flights proposed in this Petition for Exemption will be conducted below 400 feet AGL or as otherwise permitted in a granted Certificate of Authorization. Furthermore, all flights will be conducted within Visual Line of Sight, as is currently advised by the Federal Aviation Administration and Academy of Model
Aeronautics

. 6 Additionally, the PIC will only operate the Petitioner’s sUAS if weather conditions permit safe operations. The judgement of “Safe Weather Conditions” will be determined based on several standing classifications developed by the Federal Aviation Administration. These include operations being conducted under the Visual Meteorological Conditions (“VMC”) rules.

As stated previously in this Petition, Manny Rodriguez will strictly adhere to the FAA’s V isual F light R ule s,

an d obviously, to be following Vis ual Flight Rules, Manny Rodriguez will have to first satisfy the Visual Meteorological Conditions associated with VFR flights. In particular, the Petitioner will be cognizant of the boundary between Visual Meteorological Conditions, which allow for Visual Fligh t Rules, and Instrument Meteorological Conditions, which require Instrument use. Specifically, Manny Rodriguez will be considering the VMC Minima pertaining to Visibility, Cloud Ceilings, and Cloud Clearances associated
with airspace below 400 feet AGL, where the Petitioner’s sUAS will be flying. Thus, the Petitioner will only operate when visibility is at least 3 statute miles from the PIC and at a minimum of 500 feet below and 2,000 feet horizontally from a cloud

. 8

In addition to the particular flight conditions stated above, it should also be noted that the flight crew will always make an assessment of the current situation for each, specific flight. This assessment will
conclude with a determination of the relative safety of the flight and any risks or hazards that may be present. If this assessment finds that the flight will be too dangerous or that there are too many hazards or risks associated with the flight, the flight crew will no t take off. Furthermore, in order to maintain the safety of the general public, flight operations utilizing the Petitioner’s sUAS will only take place after permission is granted to the Petitioner by the landowner, property owner, or other controlling

rep resentative. All current FAA regulations not covered within this petition will be followed as well as all local and state rules surrounding flights near or around people. Additional information on the parameters dictating flights near people can be found below in the “ Proposed Conditions of the Exemption .”PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 18



### Unmanned Flight Operations

When conducting commercial flight operations under the pro posed applications in this Petition for Exemption , a commitment to safet y will always be paramount. Additionally, with the goal of each flight to accurately collect valuable aerial data in an efficient manner, it will be vital for all flights to be safe for several reasons, including;

 The safety of the Manny Rodriguez Flight Crew will be necessary for continued flights.  The safety of the general public will be necessary for continued operations.  The safety of the aircraft will be necessary for continued commercial endeavors.

Furthermore, in an ef fort to supply the Agriculture

, Cinematography

, Infrastructure

, Insurance

, Land Inspection

, Real Estate

, and Search and Rescue industries with valuable data, it will be imperative for all Manny Rodriguez flights to be conducted in a safe and professional manner so as to not ris k the safety of the flight crew, general public, or aircraft as well as to avoid damaging people or property operating in the National Airspace System or on the ground below.

To ensure the safe and professional execution of each sUAS flight, all flights will be conducted utilizing at
least a two

- person flight crew. This flight crew will consist of an adequately

- trained (“ Unmanned Flight
Crew ” ) PIC and VO. For specifics pertaining to the standard operating procedu res utilized by the Petitioner under the proposed Petition for Exemption and for more details on training, please see
Exhibits 1

- 4

. 

## Aircraft and Equivalent Level of Safety

As is stated in the FAA’s Section 333 Exemption Guidelines, Petitioners for Exemption must show that their proposed commercial, sUAS operations provide a level of safety at least equal to that provided by the rule from which the Petitioner seeks an exempti on

. 6 As will be highlighted below, the request for this Exemption by the Petitioner is fortified by its commitment to safety. Furthermore, the operation of sUAS by the Petitioner, using the previously stated flight crafts and operating within the above

- stated

use

- cases under the rules, regulations, and limitations stated herein, should be permitted under the proposed exemption. Reasoning for this can be derived from the strict adherence to existing regulations
from the Fe deral Aviation Administration as well as the adoption of the following conditions ; each providing at least an equivalent level of safety as is provided by the existing rule.



## National Security

In addition to the arguments supporting the Petitioner’s exemp tion from certain rules contained in 14
C.F.R. , it is also important to note that the granting of this petition and in turn, permission for the
Petitioner to conduct commercia l sUAS flights, will not prese nt a national security threat. As has been stated in this Petition

, and

, as is precedent from the F ederal Aviation Administration , the PIC of a sUASPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 19

must hold, at minimum, a Recreational or Sport Pilot’s Certificate, meaning he or she has already been sub ject to a security screening by the Department of Homeland Security. 9

This provision, relating to the acquisition of a Recreational or Sport Pilot’s Certificate, points to checks already provided by the FAA and Departmen t of Homeland Security in ensuring secure aircraft operations. As is stated by the Aviation and Transportation Security Act, the Transportation Security Administration (“TSA”) must assess information in order to identify individuals that may pose a threat to transportation security and coordinate countermeasures with other Federal Agencies such as the FAA. Therefore, due to the fact it is a requirement for all PICs to be at least Recreational or Sport Pilot Certified, it can be assumed that adequate secur ity checks by the TSA and FAA have taken place prior to a sUAS Pilot conducting commercial operations.


## Proposed Conditions of the Exemption

As is noted by the Federal Aviation Administration in their, “Section 333 Petition Guidance & Checklist

, ” 3 Section 333 Exemption Petitioners are strongly advised to, “Carefully review the Conditions and
Limitations Section in the most recently granted exemptions.” 3 Due to this, the following Conditions of the proposed Exemption closely follow this guidance and mirror many of the same conditions previously noted by other exemption petitioners. The following list will highlight these conditions and establish a framework from which the petitione r, Manny Rodriguez , will conduct his commercial sUAS operations under a granted petition for exemption.

1. Proposed operations using s mall Unmanned Aircraft Systems in the United States under the granted form of this Petitio n for Exemption will be limited to the following aircraft, which all weigh less than 55 pounds including batteries and operational/technical payloads; DJI Phantom
3 Professional

, DJI Inspire 1

, and DJI Matrice 100

. Furthermore, any aircraft outside of this comprehensive list for this Petition for Exemption will have to be added to an amended version of this petition or a new Petition for Exemption must be filed with the new flight platform (s)

.

2. The proposed use

- cases/applications contained within this Petition for Exemption under Section 333 are as follows; Agriculture

, Cinematography

, Infrastructure

, Insurance

, Land Inspection

, Real

Estate

, an d Search and Rescue

. All of these flights will take place below 400 feet AGL nationwide unless otherwise advised in an
ATO

- issued Certificate of Waiver or Authorization.

3. All flights conducted by Manny Rodriguez will be below 400 feet AGL, operated within Visual Line of Sight, and have a live, GPS

- based, read

- out of al titude during the flight. Furthermore, each flight will begin with a “Zero Altitude” start point, thus creating an accurate AGL
calculation.

4. All flights conducted by the Petitioner will be controlled by a trained flight crew consisting of a
licensed (at minimum Recreational or Sport Pilot’s Certificate) PIC with a Medical Certificate or equivalent valid U.S.A. Driver’s license and a trained Visual Observer.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 20

5. All flights conducted by the Petitioner will include aircraft that are flying below the 87 kno t (100 mph) airspeed maximum, highlighted by the FAA in their guidelines.

6. All flights conducted by Manny Rodriguez will be conducted within Visual Line of Sight, during daytime flying hours, and adhere to Visual Flight Rul es under the Visual Meteorological Conditions associated with 400 foot AGL airspace.

7. The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the qualification standards set by the Federal Aviation Administration (i.e. Minimum

- Sport Pilot’s Certificate and Medical or U.S.A. Driver’s License) and by the safety guidelines and operational capabilities relating to safe sUAS operations, such as;

a. Evasive Maneuvers
b. Emergency Actions

c. Fail

- Safe Knowledge
d. Flight Skills
i. Maintaining adequate di stances from;

1. People
2. Property
3. Structures
4. Etc.

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R. 61.51(b). Additionally, a record of the PIC training will be documented and made available upon request by the Administrator.

9. Training operations will only be conducted d uring dedicated training sessions. During training, all persons not essential for flight operations will be deemed nonparticipants, and thus, the PIC will operate the aircraft with appropriate distance from nonparticipants in accordance with 14
C.F.R. 91.1 19.

10. As highlighted by the FAA, the Visual Observer’s duty is to visually observe the relevant airspace for aircraft, hazards, obstacles, structures, or the like. For this reason, the VO will not be allowed to operate the camera or other instruments on t he sUAS during flight operations. Instead, a third person will have to serve as a camera operator if the flight crew seeks a dedicated pilot and dedicated camera operator.

11. The PIC, for the duration of an unmanned flight, will be named prior to the fli ght. Due to this, once the PIC is named and a flight is begun, the PIC will not be able to transfer his/her designation as the PIC through the duration of the flight. Furthermore, the PIC is the Captain of the flight crew and will ensure that the Visual Observer is qualified to hold the VO position for the duration of the flight.

12. Each commercial sUAS flight performed by Manny Rodriguez will be planned for ahead of the flight date. This will be to ensure adequate time for all participants to prepare and to obtain allPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 21

the necessary permissions (landowners, homeowners, property owners, etc.) if any are needed. All flights will be preceded by a meeting at least one day before the flight at which all participants of the fligh t will be present. This is to ensure adequate knowledge and preparedness prior to the sUAS flight.

13. Aircraft maintenance is obviously vital for any commercial sUAS operation. It ensures safety and is necessary prior to each flight to maintain safe, eff icient, and effective flight operations. Once again, the PIC, as the captain of the flight crew, will take a leading role in inspecting the aircraft prior to flight. The PIC will likely have the most experience of anyone on the flight crew and will be in tune with the specific maintenance needs of each specific flight craft. If the PIC were to find an error in the flight craft or any of the associated systems, including the Ground Control System for example, he/she would ground the flight until adequate maintenance is completed and the aircraft is once again safe to fly. All maintenance on flight crafts utilized by the Petitioner will be noted and logged to ensure the safety of all aircraft and the people operating them.

14. Relating to the above Conditio n, anytime a flight

- critical component is replaced or anytime there is mission

- critical maintenance on the craft, the PIC will conduct a flight test of the system before completing the intended, commercial mission. Once again this flight test will be logg ed by the PIC.

15. Routine maintena nce and inspections of the sUAS will be logged by the PIC in accordance with the requirements and suggestions laid out by the aircraft manufacturer in terms of aircraft component maintenance, overhaul, replacement, inspecti on, and life limits, which are part of the supporting documents for each aircraft below in the aircraft

- specific exhibits . The logging of these maintenance/inspection checks will be included in the aircraft records and include the
total time of service an d description of work.

16. All sUAS flights will be conducted within Visual Line of Sight (“VLOS”) of both the PIC and VO at all times. Furthermore, VLOS means visual observance unaided by any device other than corrective lenses such as eye glasses or cont acts. The use of telescopes, FPV systems (for purposes of VLOS flights), binoculars, and the like will not be permitted. Also, both the PIC and VO should be in constant, verbal communication range. The use of other devices to communicate out of verbal r ange are not permitted. These devices would include, cell phones, text messaging, walky

- talkies, and the like.

17. No commercial flight missions will be executed unless it can be determined that the flight crew can complete their mission from take

- off thro ugh landing, with a reserve of 25% battery life. The Petitioner’s newest flight crafts have adaptive battery monitors and

, for this reason

, this condition will be an automated process as the Petitioner can set the default Advisory and Critical Battery war nings to 35% and 30% respectively, which will warn the PIC of the depleted battery and engage him/her to fly home and land with 25% remaining power. For all Manny Rodriguez systems without this automated feature, a watch wil l be used to monitor flight times to ensure a safe return home with adequate battery power. However, due to the revolving adoption of the newest flight platforms and the current stock of new generation flight crafts, the overwhelming majority of sUAS flig hts after the granting of this exemption will utilize a Smart Battery System.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 22

18. In the case of an unexpected obstacle or in

- flight issue, each sUAS the Petitioner operates will have the ability to abort a mission and take corrective actions.

19. The sUAS utilized by Manny Rodriguez will be programmed so that if the sUAS loses signal with the PIC or Ground Control Station during flight, the system will return to a preprogrammed GPS location located within the operating area co ntaining the flight crew. Furthermore, this failsafe can also be used in controlled situations, meaning the failsafe will be able to be engaged should something happen on the ground that disallows the PIC from bringing the sUAS back in a normal fashion. Additionally, in both situations described above, where the failsafe is either a controlled action from the pilot or an uncontrolled situation, like radio

- link signal loss, the unit will not only fly back to its preprogrammed home point, it also has the ab ility to land itself. This allows safe operations of the aircraft even in troublesome situations, such as signal loss, and prevents the unit from flying off uncontrollably or landing in an unknown location.

20. The operating documents required under 14 C.F. R. 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the aircraft anytime the sUAS is operating. Furthermore, these documents will be available for review by the Administrator or other law enforcement officials u pon request and are additionally contained in Exhibit 1, with appropriate links to the specific flight manuals of each flight craft requested in this Petition for Exemption.

21. It is always important to specify precedent when determining operating practices. For this reason, if a discrepancy exists between the conditions laid out in this Petition for Exemption and the actual Granted Exemption, the conditions laid out in the fina lized Granted Exemption will take precedent over the conditions laid out in this Petition. Furthermore, if there are no discrepancies between the Petition and Grant of Exemption, the Petitioner will follow the procedures outlined in the Operating Document ation below. Additionally, if any changes are made to the Operating Procedures and Documentation contained in this Petition for Exemption, the Petitioner will present the updated documents upon request from the Administrator. Also, should the Petitioner determine that an update or change to the procedures or documentation would affect the basis of the approved version of this Petition for Exemption, the Petitioner will either file for an amendment to the existing Exemption or create a new Petition with th e revisions.

22. As has been noted, the Petitioner will obtain written and/or oral permission from the landowners, farmers, property owners, or otherwise authorized agents for flights above their property.

23. The Petitioner will also obtain all required per missions and permits from territorial, state, county or city jurisdictions, including;

a. Law Enforcement b. Fire Departments

c. Municipal Agencies, or; d. Other Appropriate Governmental BodiesPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 23

24. The Petitioner will not conduct operations at night. Furthermore, all o perations will be conducted under Visual Meteorological Conditions (“VMC”).

25. The Petitioner is aware of the need to obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting operations under the gr ant of exemption. The Petitioner intends to fly under the Blanket COA provided by the FAA in March of 2015 for flights below 200 feet to all Section 333 Exemption holders or under a future ATO

issued COA that will be applied for by the Petitioner after re ceiving their Section 333 Exemption Number

.

26. All sUAS flights conducted by the Petitioner will be done so in accordance with airspace requirements established by the FAA and/or an ATO

- issued COA, including;

a. Class of Airspace b. Altitude Level, and potentia l;

c. Transponder Requirements

27. As has been stated, the sUAS will not be operated within 5 nautical miles of an airport reference point as noted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s Air Traffic Control is obtained, and the operation is conducted in accordance with a NOTAM as required by the Operator’s COA.

28. As stated previously, the Petitioner will follow VMC guidelines for VFR flights and as such, will fly only when there is visibility equal to, or in excess of, 3 statute miles from the PIC, while maintaining an adequate distance of no less than 500 feet below, or less than 2,000 feet horizontally from a cloud.

29. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide or as

o therwise advised in an ATO

- issued COA.

30. All sUAS craft flown by the Petitioner will be marked and identifiable by a serial number which will be as large as practicable given the relatively small size of the aircraft. The FAA has previously stated that s o long as the markings are as large as practicable given the size of a sUAS, an equivalent level of safety can be achieved.

31. All aircraft utilized by the Petitioner operate via radio frequency, which is governed by the Federal Communications Commission (“FCC”). For this reason, prior to commercial operations under a granted Section 333 Exemption, the Petitioner will ensure the radio frequency spectrum used to operate and control its sUAS complies with FCC or other appropriate government oversight agenc y rules and regulations.

32. As is stated in the FAA guidelines, a sUAS is required to yield the right of way to all manned aircraft and aviation operations at all times. This rule will be strictly followed by the Petitioner.

33. The concentration of a PIC i s necessary for safe operations. It is for this reason that the Petitioner will not allow any sUAS operations while a PIC is in a moving device or vehicle. These vehicles would include things like;PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 24 a. Cars/Trucks/SUVs
b. Boats

c. Tractors d. ATVs

34. All sUAS operatio ns by the Petitioner will be conducted at least 500 feet from all nonparticipating people, vessels, vehicles, and structures, unless the following conditions apply;

a. Protective barriers are present that adequately protect nonparticipants from flying shrapn el or debris should there be an accident. Furthermore, should a nonparticipant leave this safe

- zone, the PIC will end the flight.

b. The Petitioner has been granted permission to operate near a vessel, vehicle, or structure by the owner/controller of thes e properties. In addition to permission, the PIC will also have to perform a risk assessment of the situation and potential obstacles/flight hazards and determine the safety of the flight. If it is determined that the hazards present no risk, the PIC can start the mission.

35. The Petitioner will log and report to the UAS Integration Office within 24 hours of any incident, accident, or flight operation that occurred outside the horizontal and vertical boundaries of the operational area as defined by the COA under which the flight was operating. Furthermore, the Petitioner will report accidents to the National Transportation Safety Board (NTSB).

36. The Petitioner will provide additional flight training to PICs that may be towing objects in the event of an e xemption from 14 C.F.R. 61.315 (c) (18). In the event that the Petitioner is exempt, each PIC that is designated as being a potential candidate for flying a sUAS while towing an object will be required to undergo additional training, on top of their requi red training and certifications, that will consist of 10 hours of training flights while towing objects. These objects will be dummy banners that weigh no more than the max weight allowable to satisfy the max takeoff weight specifications as highlighted b y the manufacturer for each flight craft. Furthermore, the 10 hours of training will be required for each aircraft type, thus giving the PIC adequate training time and experience while towing obj ects with specific flight craft . This will be necessary to f amiliarize each PIC with each specific flight craft in order to learn how specific flight craft respond to towing objects, particularly with regard to downwash and wind. Additionally, of the 10 total flight hours required for training on towing objects, 5 of these hours must be in the max wind tolerances as specified by the manufacturer for each flight craft. Training in these conditions will hone the skills of each PIC and allow them to operate in the worst case scenario for towing objects, which is high wind. When conducting actual commercial flights while towing objects, the Petitioner will not conduct flights in conditions where sustained winds are more than 75% of the maximum wind tolerance of the aircraft or when there are wind gusts in excess of 75 % of the maximum wind tolerance as specified by the manufacturer for each aircraft.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 25



## Exemptions Requested & Applicable Conditions/Reasoning

14 C.F.R 21(h) : Airworthiness Certificates

Subpart (h) of Part 21 from the Code of Federal Regulations Tit le 14, Chapter 1, prescribes procedural requirements for the issuance of Airworthiness Certificates. Proposed Conditions 1, 2, 3, 4, 5, 15, 24, 27, 28, and 33 are all applicable to this particular Regulation and the FAA has found in favor of exempting

pre vious Petitions #11062, 11063, 11064, 11065, 11066, and 11067 for this portion of 14 C.F.R. Furthermore, it is the belief of the Petitioner that a sUAS operating without an Airworthiness Certificate but within the conditions stated above would provide an equivalent level of safety to an aircraft operating with an airworthiness certificate not subject to the above conditions or limitations.

Additionally, all the sUAS proposed within this Petition for Exemption are small, weigh less than 7.5 lbs, have a flig ht speed of less than 100 mph, carry no pilots or passengers, carry no flammable fuel, are
electric

- powered, are operated below 400 feet, are operated at least 5 miles from an airport, and are flown within unaided, visual line of sight of a trained and lic ensed Pilot In Command. Plus, with built

- in
fail

- safes that include GPS Guidance technologies, Return to Home Features for lost signal and low battery emergencies, and for the ability to regain radio connection with the craft after a fail

- safe is engaged, it is clear the proposed aircraft have safety features equivalent to and superior to conventional aircraft that hold airworthiness certificates. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 21(h).



### 14 C.F.R. 27 : Airworthiness Standards

- Normal Category Rotorcraft

Title 14, Part 27 of the Code of Federal Regulations creates the procedural requirements for airworthiness certification of Normal Category Rotorcraft. Due to the fact that the proposed aircraft

cont ained within this Petition for Exemption are multi

- rotor aircraft, the Petitioner seeks exemption from 14 C.F.R 27 for the same reasons stated in the request for exemption from 14 C.F.R. 21(h).



### 14 C.F.R. 43.7 : Authorized Maintenance/Repair/Alteration Pers onnel

Title 14, Part 43, Section 43.7 of the Code of Federal Regulations regulates personnel authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive mainte nance, rebuilding, or alteration. Proposed conditions 13 and 14 are applicable to this particular regulation and the FAA has found in favor of previous Exemption #11208 pertaining to this rule. Furthermore, it is the opinion of the Petitioner that the st ated rule would create a burden as the Petitioner would have to find a regularly authorized conventional mechanic or otherwise licensed personnel to sign off on an unconventional flight craft’s maintenance. More clearly,
it would be difficult to find a me chanic that specializes in Cessna Repair that is also an expert in small
radio

- controlled multi

- rotors.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 26

Additionally, it is likely that the operator of the sUAS (the PIC) would be more knowledgeable on the interworking’s of their sUAS than a regular mech anic as they likely have past RC flying experience. Particularly, the PICs working for the Petitioner will always have at least 25 hours of RC craft experience, in which time they will likely have to repair a prop for example. Due to the relative ease of replacing props on a multirotor (screw the broken one off and replace with a new one) it is not necessary for a certified or authorized individual to sign off on the repair. Instead, the repair can easily be done by authorized personnel working for the P etitioner so long as the conditions and procedures stated above, are followed. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.7.



### 14 C.F.R. 43.11 : Dispositions of Records for Inspections

Title 14, Part 43, Section 43.11 of the Code of Federal Regulations pertains to the disposition of Records for Inspections. Proposed condition number 13 pertains to this particular regulation and the FAA has found in favor of previous Exemption #11208 which contained this r ule. For the reasons stated in Condition 13 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.11.



### 14 C.F.R. 45.11 : Making of Products

Title 14, Part 45, Section 45.11 of the Code of Federal Regulations pertains to the manufacturing of aircraft and major aircraft components, including, but not limited, aircraft bodies, aircraft engines, and aircraft propellers. This particular rule requi res various procedures for marking each component with fireproof markings and, in a manner acceptable to the Federal Aviation Administration, for purposes of
identification. Proposed Condition for Exemption #30 above, pertains to this particular regulati on and the FAA has ruled on it in previous Exemption #11208. For the reasons stated in Condition #30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt
from 14 C.F.R. 45.11.



### 14 C.F.R. 45.23(b) : Display of Marks; General

Title 14, Part 45, Section 45.23(b) of the Code of Federal Regulations states that;

 “ When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, coc kpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.”PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 27

In a previous grant of exemption (Exemption #11062) it was determined by the FAA that the exemption of sUAS operators from this provision was warranted so long as the aircraft, “have identification (N

Number) markings in accordance with 14 C.F.R. 45 (c) if the markings are as large as practicable.” As is stated in Proposed Condition #30 above, the Petitioner will mark their aircraft with markings as large as practicable and therefore should be exempt from 14 C.F.R. 45.23(b).



### 14 C.F.R. 45.27 : Marking of the Aircraft

– Rotorcraft

According to Title 14, Part 45, Section 45 .27, of the Code of Federal Regulations, the operator of a rotorcraft;

 Must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail, the marks required by 14 C.F.R. 45.23.

For the same reasons stated in the request fo r exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.27. More clearly, due to Condition #30 above, which states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner r espectfully asks for exemption from 14 C.F.R. 45.27.



### 14 C.F.R. 45.29 : Size of Marks

According to Title 14, Part 45, Section 45.29, of the Code of Federal Regulations, the operator of an aircraft;

 Must display on markings on the aircraft meeting the si ze requirements of this section  2

- 12 inches high depending on the aircraft type  Width 2/3s wide as the characters are high  1/6 th as thick as the characters are high  Not less than 1/4 th the character width  Uniform

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.29. More clearly, due to Condition #30 above, which states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner respectfully asks for exemption from 14 C.F.R. 45.29.



### 14 C

. F

. R

. 61.3 : Requirement for Certificates, Ratings, and Authorizations

Title 14, Part 61, Section 61.3, of the Code of Federal Regulations pertains to the need for a Private Pilot’s license to operate an Unmanned Aerial Vehicle. The Petitioner seeks exemption from this rule to the extent that this rule requires a sUAS operat or to hold a Private Pilot’s License. Clearly, the goal ofPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 28

this particular rule is to ensure the skill of any Pilot In Command matches the operating area in which they are flying. However, it is the Petitioner’s belief that the measure of a Private Pilot’s License and the training that went into it is not necessarily connected to that Pilot’s ability to operate a small unmanned aircraft at low altitudes. Particularly, the requirement of a Private License yields potential
PICs that have been trained in multi

- thousand pound, manned aircraft, flying at high altitudes in comparison to 7.5 lbs. or less, battery

- powered craft, operated at 400 feet AGL or below. For this reason, it is the belief of the Petitioner that they be exempt from this rule as the r equirement of a Private Pilot’s license is unnecessary. Furthermore, it is sta ted as such on the FAA website. 7

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows oper ations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

The authorization of Recreational and Sport Pilot Certificates as an alternative to a Private License points to a Private License as being a non

- requirement according to the FAA’s integration office. This further evidence shows that the Petitioner should be exempt from the aforementioned regulation. Clearly, the Petitioner’s requirement of all PICs (Proposed Condition #4) to hold at least a Recreational or Sport Pilot’s Certificate yields an authorized level of t raining according to the FAA’s own website and in turn, shows that such a requirement by the Petitioner offers an equivalent level of safety as is provided by existing rules.

Furthermore, Proposed Conditions #4, 6, 7, 8, and 9, among others, show the Pet itioner’s commitment to safety and arguments for exemption from this rule.



### 14 C.F.R. 61.23(a) and (c) : Medical Certificates

– Requirements and Duration

According to Title 14, Part 61, Section 61.23 (a) & (c), of the Code of Federal Regulations, the ope rator of an aircraft is required to hold a Medical Certificate in various Pilot In Command Situations. As is stated in Proposed Condition #4 above, the Pilot in Command will have at least a Sport’s Pilot’s License and at least a valid U.S. Driver’s licens e, which has been ruled by the FAA in previously granted exemptions as a suitable alternative to a valid medical certificate for the authorized flights of unmanned systems. Furthermore, the FAA has posted on its website this new policy. 7 Due to Condition #4 above and the current FAA Policy displayed below, the Petitioner believes it should be granted exemption from 14 C.F.R. 61.23(a) and (c).

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easi er to obtain, and therefore less costly, than a private pilot certificate.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 29

 A third class medical certificate is no longer required. Now, a Section 333 operator only needs a valid driver’s license to satisfy the medical requirement. This change is consist ent with the agency’s approach for sport pilot certificate holders, who may fly light sport aircraft with a driver’s license and no FAA medical certificate. ”



### 14 CFR 61.101(e) (4) and (5) : Recreational Pilot Privileges and Limitations

In Title 14, Part 6 1, Section 61.101(e) (4) & (5), of the Code of Federal Regulations, the FAA states that;

Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— for compensation or hire or in furth erance of a business.

As can be seen on the FAA’s website (https://www.faa.gov/news/updates/?newsId=82485);

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot cert ificate.”

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA do not adhere to 14 C.F.R. 61.101 (e) ( 4) and (5) and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.101 (e) (4) and (5) because this Petition for Exemption is for the expressed purpose of conductin g commercial operations of sUAS in an effort to earn compe nsation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial sUAS flights to customers through the use of a flight crew, consisting of a Pilot In Command th at holds at least a Recreational or Sport Pilot Certificate. Therefore, in all likelihood, many PICs employed by the Petitioner will have these specific Certificates and as such, will need to be able to fly for compensation.

Furthermore, as is stated on the FAA’s own website and as is highlighted below ;

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational o r sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

Therefore, it is highl y likely that many potential PICs will have these Certificates as they are less costly and easier to obtain than a commercial Pilot’s License as an example. For these reasons, it is clear that the Petitioner should be granted an exemption from 14 C.F.R. 6 1.101 (e) (4) and (5).PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 30



### 14 CFR 61.113 (a) & (b) : Private Pilot Privileges and Limitations

– Pilot In Command

Title 14, Part 61, Section 61.113 of the Code of Federal Regulations states that;

Except as provided in paragraphs (b) through (h) of this sect ion, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an
aircraft.

Clear ly this specific regulation conflicts with the Petitioner’s desire to provide commercial sUAS flights in the United States. Furthermore, some of the Petitioner’s PICs will have Private Pilot Licenses and as such they will be operating an aircraft (the sUA S) for compensation or hire under the proposed Petition for Exemption.

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA, including a private pilot’s license

, do not adhere to 14 C.F.R. 61.113 and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.113 because this Petition for Exemption is for the expressed purpose of conducting commercial operations of s UAS in an effort to ea rn compensation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Petitioner to provide commercial s UAS flights to customers through the use of a flight crew, consisting of a Pilot In Co mmand that holds at least a Recreational or Sport Pilot Certificate (but who may also hold a Private License). In addition, the FAA has granted over 800 Section 333 Exemptions to businesses and individuals looking to provide commercial/compensation

- based sUAS flights.

Furthermore, looking at 61.113 (b), which states; A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

 The flight is only incidental to that business or emp loyment; and  The aircraft does not carry passengers or property for compensation or hire.

The Petitioner seeks exemption from these rules as it is the Petitioner ’ s goal to fly s UAS missions for compensation or hire. Additionally, the specific provision pertaining to not flying aircraft that carry property for compensation or hire is something the Petitioner would like to be exempt from as well

. Various forms of property may be carried on a s UAS, including; Camera Systems, Digital Imagery,
Sensors , and t he like.

For all these reasons

, the Petition er seeks exemption from 14 C.F.R. 61.113 (a) and (b).



### 14 C

. F

. R . 61.315(a)(c): Privileges and Limits of Sport Pilot’s LicensePETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 31

In Title 14, Part 61, Section 61.315(a), of the Code of Federal Regulations, the FAA states that;

If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section. Paragraph (c) reads the following;

You may not act as pilot in command of a light

- sport aircraft:

(1) That is carrying a passenger or property for compensation or hire.

(2) For compensation or hire.

(3) In furtherance of a business.

(4) While carrying more than one passenger.

(5) At night.

(6) In Class A airspace.

(7) In Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower unless you have met the requirements specified in §61.325.

(8) Outside the United States, unless you have prior author ization from the country in which you seek to operate. Your sport pilot certificate carries the limit “Holder does not meet ICAO requirements.”

(9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft salesperson.

(10) In a p assenger

- carrying airlift sponsored by a charitable organization.

(11) At an altitude of more than 10,000 feet MSL or 2,000 feet AGL, whichever is higher.

(12) When the flight or surface visibility is less than 3 statute miles.

(13) Without visual referenc e to the surface.

(14) If the aircraft:

(i) Has a VH greater than 87 knots CAS, unless you have met the requirements of §61.327(b).

(ii) Has a VH less than or equal to 87 knots CAS, unless you have met the requirements of §61.327(a) or have logged flight t ime as pilot in command of an airplane with a VH less than or equal to 87 knots CAS before April 2, 2010.

(15) Contrary to any operating limitation placed on the airworthiness certificate of the aircraft being flown.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 32

(16) Contrary to any limit on your pilo t certificate or airman medical certificate, or any other limit or endorsement from an authorized instructor.

(17) Contrary to any restriction or limitation on your U.S. driver's license or any restriction or limitation imposed by judicial or administrativ e order when using your driver's license to satisfy a requirement of this part.

(18) While towing any object.

(19) As a pilot flight crewmember on any aircraft for which more than one pilot is required by the type certificate of the aircraft or the regulat ions under which the flight is conducted.

The Petitioner requests exemption from numerous provisions contained in 14 C.F.R. 61.315 (a)(c). Particularly, the Petitioner requests exemption from the following subparts of 14 C.F.R. 61.315 (c); 1, 2, 3, 9, an d 18. Furthermore, the Petitioner believes that the remaining subparts (4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19) will be adhered to via proposed conditions conta ined in “ Proposed Conditions of the E xemption ” above. Specifically, subparts 4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19 are covered by Proposed Conditions 1, 6 & 24, 6, 6, 1, 1, 3, 6 & 28, 6 & 28, 5, 25, 25, and 4 respectively.

Additionally, pertaining to subparts 1, 2, 3, 9, 18, and 19, the Petitioner seeks exemption due to both unnecessary burdens on the Petitioner as well as an equivalent level of safety as is provided by these existing subparts of 14 C.F.R. 61.315 (a)(c). Arguments for each subpart are contained below.

Subpar t (1) of 14 C.F.R. 61.315 (c) states that a Sport

- Certified Pilot may not operate an aircraft if that aircraft is carrying passengers or property for hire/compensation. This is an unnecessary burden on the Petitioner as;

1. They will not be carrying any pass e ngers as they are flying Unmanned Systems, and;
2. There will be situations in which the Petitioner carries property for compensation.

The most likely of these situations will happen when a Petitioner is carrying a device or measurement tool owned by another person for compensation. This may includ e an imaging sensor owned by a third party for example. If a third party company owns the actual sensor but wants the Petitioner to utilize the tool on the Petitioner’s aircraft, the Petitioner will be flying with property for compensation. This compensation is related to the risk of loss while the camera is operating on the Unmanned System as well as the aerial perspecti ve achieved by the sensor on a s UAS that would otherwise be impossible to obtain if th e partner company only had the sensor. This example is common in many industries in which ground tools (such as cameras) a re utilized on unmanned systems. Without exemption from this rule the Petitioner would have to either purchase the 3rd par ty sensor for use on their own s UAS or forego the compensation opportunity because they cannot carry the client’s tool and thus, not get the information the client desires. For this reason, it would be a significant burden to utilize a s UAS commercially without the ability to carry multiple sensors that may not be personally owned by the
Petitioner.

Furthermore, it is the belief of the Petitioner that an equivalent level of safety would be provided if exempt from this rule because of the extensive trai ning the PIC would have on the s UAS prior to flying commercially. This training will be in excess of the existing requirement to have at least a Sport Pilot’sPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 33

or Recreational Certificate . Thus, the PIC will have sufficient manned aircraft and unmanned aircraft
traini ng to successfully operate the s UAS without endangering the public. The training procedures and training materials for the PIC can b e found in Exhibits 1 and 4 below.

In addition to subpart (1) of 14 C.F.R. 61.315 (a)(c), the Petitioner also requests exemption from subpart (2) which states that an operator with a Sport Pilot’s License may not operate an aircraft for

compensa tion. As has been highlighted previously, the directive from Congress passed to the FAA via the FAA Modernization and Reform Act of 2012 was to integrate commercial UAV operations into the National Airspace System. Furthermore, in numerous previously fil ed and granted Petitions for Exemption under Section 333, it has been stated by the FAA that;

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate.

This statement, combined with the initiativ e behind Section 333 exemptions (the commercial integration of UAV operations in the National Airspace System) shows that the FAA has found in favor of the idea that commercial UAV operations can be conducted by people who hold a recreational or sport pilo t certificate. Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R. 61.315 (a)(c), which states that a Sport

- Certified Pilot may not operate an aircraft in furtherance of a business. The FAA defines “Furtherance of a Busines s” as;

 A flight, even if incidental to your employment or the business you intend to conduct, and not required by your business or employment, would be considered “in furtherance of a business.” 10

Clearly, based on this des cription, an aerial operation that is “in furtherance of a business” would be considered a lesser form of commercialization than flights for hire or compensation as these types of flights are incidental to a business as opposed to directly related to the b usiness, which is what a flight for compensation would likely be. Therefore, it is the belief of the Petitioner that they be exempt from this rule for the same justification as is proposed regarding 14 C.F.R. 61.315 (a)(c) (1) and (2).

On top of subpart s (1), (2), & (3) of 14 C.F.R. 61.315 (a)(c), the Petitioner also seeks relief from subpart (9) which states that a Sport

- Certified Pilot may not operate an aircraft to demonstrate that aircraft for sale. The Petitioner seeks exemption from this rule as th ey will be carrying an inventory/stock/fleet of UAV aircraft in an effort to operate a commercial service business. Furthermore, this inventory/stock/fleet will turnover from time to time as new aircraft are added and old aircraft are released by the comp any. In this event it will be important for the Petitioner to have the capability of showing off the aircraft to prospective buyers so that they can get the best price for their used systems. Plus, with PICs already being heavily trained and experienced with commercial flights, there is no added risk to allowing a qualified PIC to demonstrate the aircraft for sale to prospective buyers. The demonstration after all would be equivalent or less dangerous than a commercial flight that the PIC already perform s on a frequent basis as part of their job as a commercial s UAS Pilot.

The Petitioner also seeks exemption from 14 C.F.R. 61.315 (c) (18) which states that a Sport

- Certified Pilot may not operate an aircraft while towing an object. It is the belief of t he Petitioner that they be exempt from this rule as the maximum takeoff weight of their aircraft will never exceed the max takeoff weight specifications highlighted by the manufacturer. These max takeoff weights are the maximumPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 34

weight these aircraft can c arry (including themselves) and still fly effectively. Thus, any object being towed by the aircraft will have to weigh equal to or less than the maximum allowable weight in order to maintain or come under the max takeoff weight specifications highlighted by the manufacturer. Additionally, Proposed Condition 36 f rom the “ Proposed Conditions of the Exemption ” above, highlights reasoning as to why the Petiti oner believes their commercial s UAS flights in which object s are towed, would provide an equivalent level of safety as is provided by the existing rule. Particularly, the required and additional training necessary for a PIC to become an Object Towing PIC shows the skills that would be required to tow objects.

Fu rthermore, with the continued innovation in the world of sensors, it will be necessary for the Petitioner to be able to tow objects, such as tow

- behind sensors, in order to remain competitive with their competition. Tow

- behind sensors might measure air qu ality , capture imagery, or perform various other data collection methods. Competing vehicles for these tow

- behind sensors would include ATVs, Motorcycles, Manned Aircraft, and the like. All of these potential alternatives are more expensive to operate, m ore dangerous to operate, and dirtier to operate. Each alternative would cost multiple thousands of dollars to purchase, are larger, powered by combustion engines, and carry flammable fuel. Additionally, they produce negative effects on the environment. For the reasons stated above, the Petitioner believe s they should be exempt from 14 C.F.R. 61.315 (c) (18).



### 14 C.F.R. 91.7(a) : Civil Aircraft Airworthiness

Title 14, Part 91, Section 91.7 (a) of the Code of Federal Regulations states; no person may oper ate a civil aircraft unless it is in an airworthy condition. Proposed Condition #13 pertains to this particular regulation and the FAA has found in favor of previous Exemption #11062, 11063, and 11064, which
contained this rule. For the reasons stated in Condition 13 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.7 (a) and the proposed condition offers an equivalent level of safety as is cu rrently provided by the existing rule.



### 14 C.F.R. 91.9(b)(2) : Civil Aircraft Flight Manual

Title 14, Part 91, Section 91.9 (b) (2) of the Code of Federal Regulations states;

No person may operate a U.S.

- registered civil aircraft for which an Airplane or Rotorcraft Flight Manual is not required by Part 21.5 of this chapter, unless there is available, in the aircraft, a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any
combination thereof

. Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemption s #11062, 11063, and 11064, which contained a request for exemption from this rule. For the reasons stated in Condition 20 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (b) (2). Furthermore, the proposed condition offers an equivalent level of safety as is currently provided by the existing rule as the Operating manuals aboutPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 35

which this rule pertains are available to the operator at all times on the ground, just as they would be if the aircraft was carrying the operator. Thus, any information the operator desires about the ai rcraft or its operating guidelines, can be found within documents within arm’s reach of the operator or on a digital device, such as a Smart Phone or tablet , easily accessible to the operator.



### 14 C.F.R. 91.9(c) : Civil Aircraft Marking, Placards

Title 14, Part 91, Section 91.9 (c) of the Code of Federal Regulations states; No person may operate a
U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

. Proposed Condition #30 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Condition 30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (c). Furthermore, the proposed condition offers an equivalent level of safety as is currently prov ided by the existing rule as the FAA has previously determined that exemption from these requirements is warranted provided that the aircraft “have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart c, if the markings are as l arge as practicable.” 11



### 14 C.F.R. 91.103 : Preflight Action

Title 14, Part 91, Section 91.103 of the Code of Federal Regulations states;

Each pilot in command shall, before beginning a flight, become familiar with all av ailable information concerning that flight. This information must include

—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be c ompleted, and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, othe r reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Proposed Conditions # 3, 6, 12, 1 6, 17, 20, 22, 23, 24, and 28 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule,PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 36

including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions 3, 6, 12, 16, 17, 20, 22, 23, 24, and 28 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.103. Furthermore, the proposed conditions offer an equivalent
level of safety as is currently provided by the existing rule as Preflight Planning is integral to the Petitioner’s sUAS flights and each mission will be carefully planned, taking into consideration weather, power requirements, aircraft operating guidelines, and more, as seen in the proposed conditions above.



### 14 C.F.R. 91.105 : Flight Crewmembers at Stations

Title 14, Part 91, Section 91.105 of the Code of Federal Regulations states;

(a) During ta keoff and landing, and while en route, each required flight c rewmember shall

—
(1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircraft or in connection with physiological needs; and

(2) Keep the safety belt fastened while at the crewmember station.

(b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty stat ion. This paragraph does not apply if

—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

(2) The crewmember would be unable to perform required duties with the shoulder harness fastened.

Proposed Condition #4 pertai ns to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption #11185. For the reason stated in Condition #4 (“ P roposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.105. Furthermore, 14 C.F.R. 91.105 doesn’t really apply to the Petitioner ’s aircraft as all the aircraft requested b y the Petitioner weig h below 10 lbs. and do not carry a physical crew. As such, there is no cockpit or other operating area within the vehicle where a prospective crewmember would harness themselves in. Instead, all operations of the sUAS are executed from the ground from a designated operating area, in which, each crewmember has an assigned position at which they will stand during the operation. Generally, this standing area would be near the ground station for the PIC and in a pre

- designated area (which is determined by th e PIC) for the VO. Utilizing pre

- determined standing areas for both the PIC and VO will ensure safe operating procedures of the Unmanned Vehicle.



### 14 C.F.R. 91.109 : Flight InstructionPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 37

Title 14, Part 91, Section 91.109 of the Code of Federal Regulation s states;

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

—
(1) The instructor has determined that the flight can be conducted safely; and

(2) The person manipulating th e controls has at least a private pilot certificate with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be u sed for flight instruction to conduct a flight review required by§ 61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by § 61.57 when

—
(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in comma nd during the entire flight;

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of§ 61.195(b) , and has logge d at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unless

—
(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls. However, sim ulated instrument flight may be conducted in a single

- engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when

—
(i) The safety pilot has determined that the flight c an be conducted safely; and

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

(d) No person may operate a civil aircraft that is being used for a flight test for an airline tra nsport pilot certificate or a class or type rating on that certificate, or for apart 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being check ed, is fully qualified to act as pilot in
command of the aircraft.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 38

Proposed Conditions #4, 7, 8, and 9 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, inclu ding Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions #4, 7, 8, and 9 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.109.



### 14 C.F.R. 91.113(b) : Right

- of

- Way Rules

Title 14, Part 91, Section 91.113(b) of the Code of Federal Regulations states;

(b) General. When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

of

- way, the pilot shall give way to that aircraft and may n ot pass over, under, or ahead of it unless well
clear.

Proposed Conditions #6 and 32 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption

#11 238. For the reasons stated in Conditions #6 and 32 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.113(b). Due to the fact
that all the P etitioner’s sUAS operations will take place under the guidance of a PIC and VO within Line of Sight of the aircraft, it is the belief of the Petitioner that their proposed operations offer an equivalent level of safety as is provided by the existing rule.



### 14 C.F.R. 91.119 : Minimum Safe Altitudes

Title 14, Part 91, Section 91.119 of the Code of Federal Regulations states;

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An a ltitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altit ude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 39

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2 ) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Proposed Conditions #3, 6, 25, 26, 28, 29, and 34 pertain to this particular regulation and the FAA has
found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Conditions #3, 6, 25, 26, 28, 29, and 34 (“ Proposed Conditions of the Exemption ”) above, it is the b elief of the Petitioner that they be exempt from 14 C.F.R. 91.119.

Each of the Proposed Conditions above create sUAS operations with equivalent safety to what the typical manned mission under 14 C.F.R. 91.119 would provide. Remember, when comparing to manned operations with manned flight craft, a sUAS is much smaller and light

- weight. Consider the fact that a manned aircraft weighs thousands of pounds, carries flammable fuel, and is powered by a combustion engine. Clearly, carrying out a mission utili zing a sUAS would provide for a safer operation than would a
conventional aircraft under 14 C.F.R. 91.119.



### 14 C.F.R. 91.121 : Altimeter Settings

Title 14, Part 91, Section 91.121 of the Code of Federal Regulations states;

(a) Each person operating an air craft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—
(1) Below 18,000 feet MSL, to

—
(i) The current reported altimeter setting of a station along the ro ute and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospher ic pressure in the area of operation as shown in the following table:PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 40

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under§§ 91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting:

Current altimeter setting Adj ustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

Proposed Condition #3 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on the idea that an equivalent level of safety could be provided so long as the Unmanned Aircraft w as operated below 400 feet AGL, within Visual Line of Sight, and operated with a live, GPS

- based, Altitude
read

- out. For the reasons stated in Condition #3 (“ Proposed Conditions of the Exemption ”) above, it is
th e belief of the Petitioner that they be exempt from 14 C.F.R. 91.121 because they are receiving a live,

GPS

- Altitude, read

- out on each flight, they are operating below 400 feet AGL, and they are operating within Visual Line of Sight. Furthermore, as can b e seen in Proposed Condition #3, each flight conducted by the Petitioner will begin with a zero

- altitude start point.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 41



### 14 C.F.R. 91.151(a) : Fuel Requirements for VFR Flight Conditions

Title 14, Part 91, Section 91.151(a) of the Code of Federal Regulations states;

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

—

(1 ) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Proposed Condition #17 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on an equivalent level of safety being provided by a sUAS when ending a flight with at least 25% battery life remaining. Clearly, a percent battery life remaining is a better me asure for safety when using a sUAS because the current battery capacities achieved by these types of vehicles (including all the sUASs proposed in this Petition for Exemption) often do not allow for flight times of over 25 minutes, which is
far less than e ven the reserve time limits mandated by 14 C.F.R. 91.151(a). For the reasons stated in Condition #17 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.151(a) because they can achieve an equivalent level of safety by terminating their flights with 25% battery life remaining.



### 14 C.F.R. 91.203(a) and (b) : Civil Aircraft

– Certifications Required

Title 14, Part 91, Section 91.203(a) and (b) of the Code of Federal Regulations states;

(a) Except as provided in§ 91.715 , no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used

t o comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under§ 21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter contai ning that portion of the operations specifications issued under § 21.197(c) , or an authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapter

. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft may onl y be obtained upon application to an FAA Flight Standards district office.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 42

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in§ 47.31(c) , or a registration certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issue d under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Exemptions #11062, 11063, and 11064, which contained a request for exemption from this rule. Additionally, all required paperwork will be available to the PIC and VO on the ground as these are Unmanned Systems as opposed to manned aircraft. This paperwork may be in
hard

- c opy form or available through a link on the internet, such as a Google Drive account for example.



### 14 C.F.R. 215 : ATC Transponder and Altitude Reporting Equipment and Use

Title 14, Part 91, Section 91.215 of the Code of Federal Regulations states;

(a) All airspace: U.S.

- registered civil aircraft. For operations not conducted under part 121 or 135 of this chapter , ATC transponder equipment installed must meet the performance and environmental requirements of any class of TSO

- C74b (Mode A) or any class of TSO

- C74c (Mode A with altitude reporting capability) as appropriate, or the appropriate class of TS O

- C112 (Mode S).

(b) All airspace. Unless otherwise authorized or directed by ATC, no person may operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless that aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC and intermode and Mode S interrogations in accordance with the ap plicable provisions specified in TSO C

- 112, and that aircraft is equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure altitude information in 1 00

- foot increments. This requirement applies

—
(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part from the surface upward to 10,000 feet MSL;

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon or gli der may conduct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are conducted

—
(i) Outside any Class A, Class B, or Class C airspace area; andPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 43 (ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B or Class C airspace area designat ed for an airport upward to 10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon, or glid er

—
(i) In all airspace of the 48 contiguous states and the District of Columbia at and above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the surface; and

(ii) In the airspace from the surface to 10,000 feet MSL within a 10

- naut ical

- mile radius of any airport listed in appendix D, section 2 of this part, excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designated for that airport.

(c) Transponder

- on operation. While in the airspace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equipped with an operable ATC transponder maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.

(d) ATC authorized deviations. Requests for ATC authorized deviations must be made to the ATC facility having jurisdiction over the concerned airspace within the time periods specified as follows:

(1) For operation of an aircraft with an operating transponder but without operating automatic pressure altitude repo rting equipment having a Mode C apability, the request may be made at any time.

(2) For operation of an aircraft with an inoperative transponder to the airport of ultimate destination, including any intermediate stops, or to proceed to a place where suitable repairs
can be made or both, the request may be made at any time.

(3) For operation of an aircraft that is not equipped with a transponder, the request must be made at least one hour before the proposed operation.

Proposed Conditions #3, 25, 26, and 27 pertain to this parti cular regulation. Clearly, by following the aforementioned Proposed Conditions, and particularly all the reporting requirements contained in an

ATO

- Issued COA, the Petitioner can provide an equivalent level of safety as is provided by the existing
rule an d ensure adequate compliance with reporting standards as set forth in the rule.



### 14 C.F.R. 91.403 : General

Title 14, Part 91, Section 91.403 of the Code of Federal Regulations states;PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 44

(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter

. (b) No person may perform maintenance, preventive maintenance, or alterations on an a ircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter

. (c) No person may operate an aircraft for which a manufacturer's maintenance manual or instructions
for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set forth in an operations s pecification approved by the Administrator underpart 121 or 135 of this chapter or in accordance with an inspection program approved under § 91.409(e) have been complied with.

(d) A person must not alter an aircraft based on a supplemental type certificat e unless the owner or operator of the aircraft is the holder of the supplemental type certificate, or has written permission
from the holder.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the
aforementio ned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.405(a) : Maintenance Required

Title 14, Part 91, Section 91.405(a) of the Code of Federal Regulations states;

Each owner or operator of an aircraft

—
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in p aragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ;

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.407(a)(1) : Operation after Maintenance or Alteration

Title 14, Part 91, Sectio n 91.407(a)(1) of the Code of Federal Regulations states;

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 45

(1) It has been approved for return to service by a person authoriz ed under§ 43.7 of this chapter.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existin g rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 409(a)(1) and (2) : Inspections

Title 14, Part 91, Section 91.409(a)(1) and (2) of the Code of Federal Regulations states;

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person autho rized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.417(a) and (b) : Maintenance Records

Title 14, Part 91, Section 91.417(a) and (b) of the Code of Federal Regulations states;

(a) Except for work performed in accordance with§§ 91.411 and 91.413 , each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft.
The records must include

—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; andPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 46 (ii) The date of completion o f the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return
to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propelle r, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness dire ctives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1 ) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred
with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



## Privacy

When discussing the use of s mall Unmanned Aerial Vehicles, the qu estion of privacy frequently comes up. The reason for this is clear as small unmanned aircraft, despite their incredible uses as a tool, also have the potential to be used for nefarious activities, such as spying for example. This presents a risk toPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 47

the personal privacy of individuals. Furthermore, in less extreme cases of invasion of privacy, a small unmanned craft might accidently capture imagery that would comprise someone’s privacy. Due to these potential privacy risks it is imperative for operators of small unmanned craft to use their aircraft responsibly and focus on mitigating any of the potential privacy risks their aircraft creates. The Petitioner is particularly aware of the privacy concerns of individuals and due to this is extremely
focused on providing privacy not only for individuals, but also for customers. Due to this the Petitioner will incorporate various privacy initiatives such as asking permission of all participants of a commercial UAV flight and obtaining consent from all non

- part icipating parties who may have been captured in filming.


## Public Interest and Safety

According to the Federal Aviation Administration Guidelines for Section 333 Exemptions there are three main criteria a successful Petition for Exemption under Section 33 3 should have;

1. The Petitioner must submit a request for exemption from a rule or set of rules contained in 14

C

. F

. R

. that the Petitioner believe s will be a burden for their operations.

2. The Petitioner must provide a level of safety at least equal to that provided by the rule from which the Petitioner is seeking a n exemption, and;

3. The Petitioner’s request must be in the Public Interest.

To satisfy these main guidelines, the following information will cover the justification of the proposed commercial opera tions under Section 333 requested by this Petition. More clearly, the following arguments will show how each of the proposed applications/use

- cases are in the public interest and promote safety.

Specifically, the sUAS flights proposed in this petition wil l increase safety for the following applications; Agriculture, Cinematography, Infrastructure, Insurance, Land Inspection, Real Estate, and Search and

Rescue. Furthermore, it wi ll be seen that the use of sUAS by the Petitioner will also promote safety and reduce negative environmental impacts. This will be achieved because of the lower risks associated with a small, plastic, battery

- powered sUAS, as compared to a manned, multi

- thousand pound, combustion

engine

- power ed, flammable

- fuel

- carrying aircraft. Plus, with most sUAS data capture happening at low altitudes, because of the enhanced da ta resolution possible at low altitudes, customers of sUAS services are getting better, more accurate data, while at the same tim e the public is avoiding the potentially hazardous practice of ultra

- low

- flying manned aircraft. Clearly, the combination of better, more accurate data, coupled with the enhanced safety of a sUAS over manned aircraft, produces a viable commercial operatio n that promotes the public interest. Evidence of this can be found in the industry

specific examples below

. In addition to the aforementioned safety benefits and promotion of public interest s, it should also be
noted that all the sUAS aircraft utilized by the Petitioner satisfy the directives passed to the Federal Aviation Administration by Congress in t he Reform Act of 2012 . Specifically, all of the Petitioner’s aircraft satisfy the size, weight, speed, operating capabil ities, proximity to airports, proximity toPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 48

populated areas, and visual line of sight rules and requirements laid out by Congress. Furthermore, due to the FAA precedent of requiring, at minimum, a Sport Pilot’s Certificate, the FAA can be assured that
all commercial flights proposed in this Petition do not pose a threat to National Security as all PIC’s will have already been vetted by the Department of Homeland Security. For these reasons and for the numerous arguments contained herein, this Petition for Exemption provides strong justification for approval of commercial operations for the above

- stated sUAS in the above

- stated applications and use

cases under Section 333, pursuant to the operating procedures and requirements described herein.

Furthermore, contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate commercial sUAS flights into the National Airspace System. With this initiative it is definitive that Congress believ es that the integration of commerci al sUAS into the National Airspace System is within the Public Interest as they are, obviously, elected representatives of the public assigned with the duty of driving policy that promotes the Public Interest. Thus, in addition to the industry

specific ex amples below, it should also be considered t hat the integration of all sUAS , pursuant to their safe integration to the NAS and providing of at least an equivalent level of safety as is provided by the current FAA rules, is inherently within the public inte rest.

Please look below to find more detailed descriptions as to why each of the applications highlighted above can provide a benefit to the public as a whole and r easons why the exemption would not adversely affect safe ty

.



### Agriculture

Precision Agriculture is an industry that has seen a significant influx of sUAS use over the past few years.
With this influx of Unmanned Aeria l Vehicle Technologies, farmers and their Ag partners have become more efficient and effective in making various Ag

- related management decisions.

There is an adage that points to the importance of agriculture to the public that reads, “...once in your
life you need a doctor, a lawyer, a policeman, and a preacher, but every day, three times a day, you
need a farmer.” 13 This adage really highlights the importance of agriculture to the public as a whole, as the Ag industry, and particularly farmers, are the p eople who provide the general public with one of their three essential needs, food.

What sUAS provide to the Ag Industry are a method by which to collect information and make management decisions that are more data

- driven and thus, more effec tive. Conside r the use of sUAS to provide targeted scouting and aerial imaging/mapping to farmers and their Ag partners (Agronomists, Crop Consultants, Seed Dealers, etc.).

Every year millions of acres of farmland are scouted by a variety of people, whether it is the farmers themselves, or an Ag partner of theirs, such as a Cooperative Agronomist, Crop Consultant, Field Intern, or other third party Ag partner. The idea behind scouting is to collect in

- season information about the crops and fields in question. A s an example, a typical crop scouting intern w ill get a set of field map s from their boss at the Coop every morning. These field maps will be for a variety of fields and crop types around the area and owned by a variety of farmers. The task of these interns i s to go out in those fields and collect information relating to; Nutrient Deficiencies, Insect Pressure, Plant Diseases, Compaction,PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 49

Plant Populations, and the like. They then take this information and report back to their agronomist or directly to the fa rmer. The farmer then takes this information and makes management decisions based
on it.

As an example, the scout might take a tissue sample while in the field, send it to the lab, and receive the results. The results of the field in question may be lo w on a variety of nutrients (ex. Macro Nutrients

– Nitrogen, Phosphorous, Potassium; Micro Nutrients

– Boron, Sulfur, Manganese, Zinc, etc.). The farm will then take this information and realize that they are low on Nitrogen and Boron and that they should make a fertilizer application of these two nutrients to improve their crop.

The example above really highlights how a Precision

- focused farmer utilizes information to make a management decision and thus, increase yields and grow more food. This is obvi ously in the public interest as it is estimated by the UN’s Food and Agricultural Organization (“FAO”) that by the year 2050 Global Food Production will have to increase by 70% of where it is today in order to feed a population that is estimated to grow to over 9 billion. 14

Where sUAS come into play is that they provide even more efficiency and data

- driven decision

- making than we even use today. Why is this? It is because a sUAS can provide a new perspective to look at agricultural crops and in turn provide a new data

- set from which information can be derived and decisions can be made. Consider the same example as we highlighted above, with the crop scout walking a set of fields, taking a tissue sample, and returning the lab data to the farmer so that the
farmer can make an In

- Season management decision. Now consider this example if that crop scout were equip ped with the same types of sUAS utilized by the Petitioner.

First of all, the scout would be much more efficient. A recent study at the University of Wisconsin

Whitewater showed that scouting with a sUAS was up to 80% more efficient than walking an entire
field. 15 Considering this efficiency fact alone, a scout is going to be much more efficient each day, which allows him/her to scout more acres and thus provide more information to m ore farmers to make data

driven decisions and produce more food as a whole. However, efficiency is not the only benefit.

In addition to efficiency, a scout can also be more targeted, meaning they can pinpoint areas of the field
most in need of a th orough walk

- through and go straight to those spots as opposed to walking randomly through the field (which is the standard practice for many scouts). By gaining an aerial perspective with a sUAS, scouts can view the entire field in a video or picture quic kly and in turn, see blotches of discoloration or diseased crop instantly. Using the internal GPS Guidance System onboard the aircraft, this scout can also georeference their imagery, meaning each picture they take can be tagged with a
Geo

- coordinate (Lat itude and Longitude). This allows them to pinpoint an area of distress in the fi eld, get the geo

- tag, input it i nto their Smart Phone or Tablet, and walk straight to that area of distress. This is both efficient and vital to the farmer and his crop. Whi le a typical crop scout might completely miss a distressed area of a field (due to the lack of an aerial perspective), a targeted scout with a sUAS is going to have the opportunity to point out all the issues in the field and in turn manage those areas to minimize the damage (yield loss).

The same University of Wisconsin

- Whitewater study that found the increased eff iciency statistics
associated with sUAS use for crop scouting also found that when sUAS crop scouting is coupled with the recommended manageme nt applications, farmers see, on average, a 7

- 10 bushel increase in production (corn). 15 This is important for a variety of reasons. First, 7

- 10 bushels turns into a huge number when itPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 50

is extrapolated across corn acres. On a 1,000 acre corn farm, a 7

- 1 0 bushel increase is an extra 7,000

- 10,000 bu., which significantly drives down per

- bushel input costs. Additionally, at today’s corn price of about $3.70, that 7

- 10 bushels is roughly a $26,000

- $37,000 revenue boost for the farm.

With the majority of f arms in America (87% according to the EPA’s 2007 Ag Census) 16 being individually or family owned, those revenue increases and cost savings are putting more money into the pocket of the American farmer. In general, most farmers then spend this money in a v ariety of ways that leads to positive impacts on the public as a whole. When a farmer goes out and buys a new tractor after a bumper crop, he is supporting workers in places like Racine, WI (Case IH) and Moline, IL (John Deere). When he goes out for a st eak dinner he is supporting local restaurants. When he buys a new vehicle it is
often an American

- made/designed truck. Furthermore, the farmer can do all of this by increasing the amount of food he/she grows and thus provide more sustenance for the world

. In addition to the basic benefits provided by a sUAS in terms of efficiency and targeted scouting of problem areas, there is also the benefit of using more advanced payloads to pull even more information from an aerial assessment utilizing a sUAS. Consider the increasing popularity of Near

- Infrared and Thermal Infrared Imaging payloads. Both these payload types provide information to the farmer that can help in management decisions and management practices.

A Near Infrared Imaging Payload, like the Tetracam ADC Snap or Micasense RedEdge for example, can provide information relating to the Near Infrared light reflectance bouncing off an Agricultural crop. This data is not viewable to the naked eye and is not “capturable” by a standard visible

- lig ht spectr um digital camera . However, this data can be extremely important and suggest crop stress within a field. By utilizing a sUAS, an operator like the Petitioner could provide a new data layer to farmers and agronomists that could help them determin e plant stress within their fields and map it according to the georeferenced, stitched imagery. Additionally, this type of imagery could also assist in management practices. With a stitched orthomosaic, like the ones created using NIR & georeferenced Ima gery, farmers can create management zones in their fields using Ag software and even create georeferenced prescription maps, which are utilized to variable

- rate fertilizers and chemicals onto fields.

Using this type of data and software minimizes over an d under application of chemicals and fertilizers and ensures the right amount of product is applied to each acre of the field. This will serve the public interest by creating a healthier environment with less runoff and water contamination as well as prov ide for more sustainable farming practices. Plus, all of this is done by making data

- driven chemical and fertilizer applications derived from sUAS Imagery, which in turn saves the farmer money by using the correct amount of product and ensures maximum yie lds by optimizing the application so that each acre of farmland receives exactly the amount of product it needs based on plant stress.

The above example mostly pertains to Precision Agriculture, however it should be noted that there are a variety of applic ations in agriculture outside Precision Agriculture that can also be positively impacted by sUAS use. Cattle operations as an example can monitor the health of their cattle by flying over their herds with thermal cameras. Plant operators can monitor the temperature of their grain piles by utilizing these same thermal cameras in much the same way. So clearly, there are many applications in
the A g Space that could utilize sUAS

. Furthermore, it should also be considered that these steps forward in effic iency and management practices are done while utilizing a safe and effective sUAS Tool that is not only maintaining the safety ofPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 51

the National Airspace but also taking into consideration customer and public privacy as well as eliminating the risks associat ed with the alternative form of imagery capture using a manned aircraft.

Referring back to the 4

- D analysis of UAV use, it is clear that the agricultural applications of data capture point to the use of UAV systems over manned aircraft because;

 Dull

– Ag flights require repetition as crop stress and/or animal health needs to be checked frequently. In some applications, daily or even hourly flights may be necessary. Due to this requirement of high repetition, a sUAS is well suited for the job over a mann ed aircraft, which would basically require a full time pilot on

- call 24 hours a day.

 Dangerous

– Ag flights have the potential to carry a high degree of risk, especially when flying low over crops or cattle. Really, any low altitude flight in a manned a ircraft is more dangerous than a high altitude flight because of the increase in obstacles and less margin for error. It is for this reason that Crop Dusting is a dangerous industry as pilots are operating
manned aircraft at altitudes much lower than thei r Private and Commercial Pilot counterparts. Furthermore, utilizing a sUAS fly

- over in agriculture can produce safer operations when compared to the alternative. Consider flying over cattle for example. Flying over a cattle operation with a sUAS can be a much safer cattle management practice than actually having a human monitoring or checking the animals while in the herd. Human interaction in a large herd could potentially cause a stampede or more likely, an aggressive animal bucking or otherwise injur ing a human.

 Dirty

– Ag flights have the potential to be carried out in hazardous environments. As stated above, operating within a cattle herd with several aggressive bulls is a hazardous environment and an environment which is better navigated by a no n

- human, such as a
sUAS.

 Deep

– Ag flights can sometimes be beyond the range of manned platforms. First, sUAS have the ability to fly at lower altitudes and thus capture higher resolution data than what a manned aircraft could do. Additionally, flight s around structures on a farm or near a farm (such as silos, barns, radio towers, etc.) could potentially be hazardous for a manned aircraft
while a micro

- drone has a lot more maneuverability in tight spaces.

Therefore, the promotion of the public intere st described above coupled with the enhanced safety provided by sUAS flights in Agriculture, strongly supports the granting of this petition.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Agricu lture Industry as being within the public interest.

 Exemption Numbers:

o 11110

o 11136

o 11167PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 52

o 11192

o 11222



### Cinematography

The Aerial Cinematography Industry is an industry that has been operating for many years to capture
cinema

- quality footage from low altitudes. Initially this type of cinematography was captured using fixed wings and helicopters, but in more recent years, the business has started to utilize UAVs. First, large, gas

- powered helicopters were used and then, in the last couple years, small Unmanned Aerial Vehicles. The reason the industry has transitioned to these small aircraft is because newer UAV systems
ha ve been able to capture the quality video the industry is looking for but at a much lower cost and with significantly lower risks.

One of the reasons manned aircraft cinematography is so expensive is because of the dangers associated with flying a 6,000 pound aircraft, filled with flammable fuel, powered by a combustion engine, at low altitudes and over people. The insurance costs alone for these types of activities are high and accidents have happened in the industry. Some of these accidents have even lead to casualties. Earlier this year 10 people died when two helicopters crashed while filming the French Realty Show, “Dropped.” 17 Whenever you have manned aircraft operating at low altitudes there are added risks. These risks include ground structure s, confined spaces, and more. Additionally, when you have manned aircraft, any accidents are much more catastrophic than if you had the same situation with unmanned aircraft. Once again, this is because of the size and flammable fuel carried on

- board man ned aircraft. A
small Unmanned Aircraft does not have the se attributes, plus, because there are no people on board, the chances of causalities is lower because there is no pilot.

It is important to remember that the weight of the UAVs utilized by the Pe titioner will weigh no more than 7.5 pounds and contain no crew, flammable fuel, or combustion engine. This limited weight and size will significantly reduce the potential for casualties or mass property damage in the case of a crash. Furthermore, the us e of electric power by the Petitioner’s UAVs is much more environmentally

- friendly than that of a manned aircraft, which is carrying a significant amount of unnecessary weight using
carbon

- based fuel sources. Therefore, in addition to the increased safety obtained by a UAV performing aerial cinematography, there is also the added public benefit of a healthier environment.

Furthermore, while traditional aerial cinematography utilizing conventional aircraft can perform in close proximity to people and p roperty, it should be pointed out that a UAV is even safer than the traditional methods because of the limited size, weight, speed, operating conditions, and safety features included on the proposed aircraft within this petition. Additionally, as is highl ighted in the FAA Modernization and Reform Act of 2012, the integration of UAS into the National Airspace System is inherently in the public interest so long as it can be accomplished with at least an equivalent level of safety as is currently provided by existing FAA rules and regulations.

On top of this, the utilization of sUAS in the Aerial Cinematography Industry falls in line wi th the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning
for this can be seen below;PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 53

 Dull

– Aerial Cinematography is an industry that requires repetitive flights. There are often multiple takes of the same scene in order to get the perfect shot with the perfect lighting. For this reason, the same flight has to occ ur several times in a short time period. This isn’t necessarily efficient for a manned aircraft because it needs to stay aloft during filming and due to this, wastes time and fuel waiting for successive shots. A UAV on the other hand can land in
between shots and use significantly less power. Plus, because of the inherent risks of flying at low altitudes for manned aircraft (structures, people, obstacles, etc.), repetitive shots require repetitive risky flight operations.

 Dangerous

– Aerial Cinematogr aphy is almost always done at very low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore aerial cinematography flights using manned
aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damag ing in the case of a cras h.

 Dirty

– Some aerial cinematography is extreme in nature and may include things like airborne
obstacles . While the Petitioner’s UAV system would be maintaining a safe distance from this hazardous environment and remaining within line of sight, it i s imp ortant to consider that unpredictable accidents can happen in which a bird might fly into a prop as an example. In this situation it would obviously be better to have a small unmanned craft than a large, manned aircraft, carryin g a pilot and flammabl e fuel. As was seen in the Miracle on the Hudson Incident, birds can have a devastating effect on an aircraft if they damage a prop or get sucked into an engine.

 Deep

– Some aerial cinematography might require capabilities that only an unmanned aircra ft can perform, such as flying in extremely close proximity to structures or other obstacles at low speeds. This type of application would be impossible for most manned aircraf t and if not impossible, fair ly dangerous. For this reason an unmanned aircraf t would be required.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Aerial Cinematography Industry as being within the public interest.

 Exemption Numbers:

o 11540

o 11153

o 12031



### InfrastructurePETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 54

Contained in the FAA Modernization and Reform Act of 2012 was Congress’ clear initiative to integrate commercial sUAS flights into the Nation al Airspace System. With this initiative it is definitive that Congress believ es that the integration of sUAS into the National Airspace System is within the Public Interest as they are, obviously, elected representatives of the public assigned with the d uty of driving policy that promotes the Public Interest. Furthermore, as it pertains to Infrastructure Inspection specifically, it should be not ed that the utilization of sUAS is perfectly in line with Dull, Dirty, Dangerous,
and Deep operations that the 4 D's of UAV Intervention have highlighted as suitable for Unmanned Aerial Systems. In particular, it can be seen that sUAS operations in the Industrial Inspection Industry are often;

 Dull

– Flights in the Inspection business are repetitive in nature, which means multiple flights and flight operations will have to be conducted in close proximity to obstacles, such as industrial structures. The necessity of repeated inspections requires an on

- demand flight craft that can be called upon instantly to prov ide a visual inspection. It is for this reason that a sUAS is perfectly designed for such operations and why manned aircraft are not.

 Dangerous

– Obviously, visual inspections of infrastructure are inherently dangerous operati ons. This is the case becau se industrial inspections are generally of standing structures, such as water towers, bridges, cell towers, poles, power lines, etc. All of these industrial structures are standing obstacles that provide a hazard to low flying aircraft, and particularly t o large, manned,
low

- flying aircraft. Therefor e, it is better to use a small unmanned aircraft because operations are less risky due to the smaller size of the aircraft which increases a Pilot's margin for error.

 Dirty

– Industrial areas can often time s be hazardous environments that pose potential health and safety threats to people and aircraft. For this reason it is much better to send in a small, unmanned aircraft than a large, manned aircraft. Consider a hazardous materials plant. Obviously it w ould be much better to have a robot flying over the plant than an aircraft carrying a person who could potential breath in fumes.

 Deep

– For some industrial inspections, the inspection flight might only be able to be carried out by an unmanned aircraft d ue to the technology and maneuverability requirements of the flight. Consider an industrial inspection of a wind turbine as an example. Wind Turbine Inspections take place in extremely hazardous areas for manned aircraft due to the many obstacles (all th e turbines) in a confined airspace. In order to get a good look at the Turbine and its blades, a
close

- proximity flight would be required, which would take extreme maneuverability in small spaces, which just isn’t possible with most manned aircraft. Addi tionally, it would be beneficial to have some sort of object avoidance technology in an environment like a wind turbine inspection situation. However, manned aircraft do not have this precise technology in most aircraft and instead, most flights are manua lly piloted. Unmanned craft do have this technology however and one of the Petitioner’s aircraft, the DJI Matrice 100 has this option available through Guidance technology, developed by DJI. This makes close

- quarter flights much safer.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 55

Thus, the use of this type of technology coupled with a UAV’s superior maneuverability, make a sUAS the perfect tool for industrial inspections.

Furthermore, it is important to look at the current alternatives for Industrial Inspections when judging the relative safety p rovided by a sUAS inspection. The most common of these various alternatives are ground

- based inspections, which are limited in effectiveness, crane

- lift inspections, which are highly dangerous and have a limited reach, physical climbing of the structure, which is dangerous and slow, and inspections conducted by manned aircraft, whi ch are typically flammable

- fuel

- filled, combustion

engine, helicopters. A sUAS inspection is superior to each of these alternatives as it is at least as safe and in most cases, m ore safe than the aforementioned alternatives and it doesn’t fall victim to the various shortcomings of each of these substitute options.

Take ground

- based inspections as an example. O ne of the current inspection strategies used on
turbines is the use o f a telescope to find scorch marks on the turbine blades. Clearly, this would be a less effective strategy than utilizing an unmanned aerial vehicle. Consider the resolution you’d have looking though a telescope at a wind turbine blade a couple hundred f eet away as compared to a 4000x3000 pixel Ultra

- HD image from 5 feet away using a UAV. Plus, a 4K image can be zoomed in on and remain in high resolution, meaning you could literally zoom in on your images from the UAV as if you were only a few inches awa y from the actual scorch mark.

Furthermore, consider the significant safety issues that are brought about by some of the other alternatives of infrastructure inspec tion. Using a lift for example exposes inspectors to electrocution risks, tipping risks, and more. Plus, with the li mited reach achievable by a lift, you often can’t lift an inspector high enough to inspect an entire s tructure. This is true of radio towers as an example. Many
of the lifts available on the market cannot reach more than half way up most radio towers , which means much of the tower cannot be inspected. A study from the Electronic Library of Construction Occupational Safety and Health found that, on average, 26 construction workers die each year resulting
from the use of aerial lifts. 18 Causes of death include, electrocution, boom collapse, falls, and more. In total, aerial

- lift

- related deaths account for 2

- 3% of construction related deaths each year. 18

Another dangerous strategy used for inspections is the physical climbing of infrastructure. This is typically done with ropes and straps. This is obviously dangerous as you have humans dangling high above the ground, where they are at risk of serious if not fatal injuries in the case of a fall. Plus, any poor weather that bl ows in during one of these climbs exposes these inspectors to various risks, including electrocution. Clearly, the use of an unmanned aircraft would be much safer than someone hanging off the side of a cell tower, water tower, or wind turbine as an exampl e. In fact, OSHA, just this past year (2014) started reclassifying and reevaluating how it investigates worker injuries and deaths in the tower climbing industry, which has been dubbed the most dangerous job in America. In August of 2013, four tower clim bers died in a two week span across the United States

. 19 When you consider that the entire industry is made up of about 10,000 people, you can see the dangers associated with this industry and why the use of unmanned systems is needed.

Finally, when looki ng at the inspection strategy of using manned aircraft (typically helicopters) you can see the risks. First, the goal of most infrastructure inspections is to get a close

- proximity view of a structure. This goal in and of itself is dangerous for a m anned aircraft as it requires a close flyby to a structure. Additionally, many of the flights in the infrastructure industry require close proximity to morePETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 56

than one structure. Consider the practice of power line inspection and the use of helicopters. Not on ly do these aircraft have to stay focused on the power pole they are next to, they must also pay attention to all the other poles and lines in their vicinity. Unfortunately, sometimes mistakes are made and typically the results are catastrophic, with fata lities and complete loss of the aircraft. The book Helicopter Crash Litigation by Gary C. Robb highlights the problem of helicopter accidents and the relatively frequent rate at which accidents occur. Specifically, it was found that, “from 2001 to 2005, the accident rate for civil helicopter use per 100,000 flight hours was forty percent (40%) higher than that for general aviation fixed

- wing aircraft. 20 The helicopter industry itself has acknowledged that the current helicopter accident rate is "excessive and unsustainable .” 20 Considering this fact, it should be noted that helicopters, which are already statistically more prone to accidents than fixed wings, are the vehicle of choice in the utility industry. It should also be noted that the environments presented by the utility industry are even more dangerous than general helicopter airspace due to the increase in obstacles and close proximity to infrastructure.

Taking all of this into consideration, it is clear that the use of unmanned aircraft for th e purpose of infrastructure inspection provides a public service while maintaining, and most often exceeding, the current safety achieved by the present rules and regulations governing the infrastructure inspection industry.

Accordingly, the Petitioner res pectfully asks for exemption in order to commercially operate sUAS aircraft in the Infrastructure Inspection Industry.

Furthermore, it should also be noted that the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Infrastructure Inspection Industry as being within the public
interest.

 Exemption Numbers:

o 11865

o 11813

o 11721



### Insurance

Another industry that is going to see huge potential in the next couple years through the utilization of sUAS aircraft is the insurance industry. One of the reasons for this is the obvious benefit an aerial perspective can be when assessing an insurance s ituation, be it a car accident, crop damage, building collapse, or the like. The ability to get above the insured asset allows for a clearer perspective of the situation and provides a bird’s eye view of what happened. This allows for more accurate insur ance estimates and in turn, more accurate payouts.

Using the example of crop insurance, it is clear to see the public benefit of utilizing sUAS aircraft for the purposes of insurance.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 57

The crop insurance industry is a big bus iness . Every year acres of a variety of crops are insured from loss with large crop insurance agents throughout rural America. In the situation of a large thunderstorm or Tornado coming through an area, consider the amount of damage that can be done to a corn crop. If
the corn is laid flat from high winds or is damaged significantly from hail, the farmer is going to experience some type of yield loss. The payout that farmer receives is going to be dependent on the extent of his yield loss as is determined by an insurance adjuster. To determine the farmer’s loss an adjuster might use a variety of strategies, including; remaining population counts, standard deviation calculations, and the like. However, when a large swath of area is damaged by a storm, insurance adjusters are sprea d thin trying to get accurate estimates for every field in the area. This can lead to overestimates, underestimates, and in general, incorrect or otherwise errored payouts. This can lead to losses for the insurance company, losses for the farmer, and pre miums that are based on payouts that may be inaccurate.

However, by utilizing sUAS aircraft, this could change, as the use of UAVs and software could allow for more efficient, automated practices. As an example, a software program that can use counting programs or image recognition technology to estimate losses would be much more automated and potentially more accurate than a team of adjusters who all might have slightly different biases when making assessments. Furthermore, the estimates and payouts as a whole across an entire insurance company would be much more consistent, as the same software is reading all the imagery captured and thus, automation allows for consistency and confidence in operations.

The crop insurance example is just one example o f how the insurance industry can benefit from the use of sUAS aircraft, however

, this same principle can be see across a variety of applications in the broader insurance industry. The public benefit of this is clear, as having more accurate and consistent payouts makes insurance companies more efficient and thus, premiums are more accurate.

Furthermore, the insurance industry is another industry that sUAS should be used for according to the 4
D’s.

 Dull

– The insurance industry is another industry that may require repeated flights of the same

area or on

- demand flights. Consider crop insurance. In the situation where a small pocket of a country received straight line winds, only a couple farms or ev en a couple farm fields are actually affected. Therefore, only one or two fields may need to be flown that day. It would be much better to have a UAV in the adjuster’s vehicle so he can fly on

- demand that day only where there are issues, as opposed to hi ring a manned aircraft to fly over and maybe only take a picture of one or a few fields. Furthermore, weather events may be sporadic, meaning as the adjuster goes from farm to farm, he isn’t sure if there is extensive damage or not and therefore
it would be an expensive gamble to send a plane up when there isn’t a certainty that there is extensive damage to film.

 Dangerous

– Commercial sUAS Insurance flights might also be dangerous. Consider a damaged building or structure. It may be better to fly th at dangerous structure with a small unmanned craft just in case that structure was threatening to collapse.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 58

 Dirty

– Consider a hazardous spill that came as a result of a derailed train or overturned semi

trailer. This example is an insurance event in which an adjuster is going to want to assess the damage while avoiding a dangerous environment. Noxious fumes may be in the area and as such, the adjuster might want to fly the area with a sUAS.

 Deep

– Once again, sUAS allow for operators to capture hi gh resolution data at low altitudes. This is true in the Insurance Industry as well and low altitude flight can be especially dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in
confined areas can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight. Consider a grain facility that is damaged in a tornado. That facility should be inspected a t low altitudes, but there are a variety of ob stacles, such as grain towers and cables, that would pose a threat to a manned aircraft.

Additionally, the following previously granted exemptions point to the FAA’s acceptanc e of sUAS use in
the Insurance Industry as being within the public interest.

 Exemption Numbers:

o 11293

o 11857



### Land Inspection

The Land Information Industry is an industry poised to gain a lot from the utilization of sUAS airc raft. The aerial perspective these units can provide to a land surveyor or developer, is enormous. Land Information covers a broad range of land evaluation applications. One of the main applications that is currently being used is stitched, 3D mapping, which allows for operators to visualize a landscape in highly accurate 3D form. This allows for accuracy in the centimeter range, which can help land managers determine tile lines in agriculture, engineers develop drainage ditches for streams, planning

co mmissions create plat maps for new developments, and architects design new building construction.

All of these applications are in the public interest. A land manager putting in tile lines in his agricultural fields helps quell runoff and erosion issues, which leads to higher yields, a healthier environment, and less pollution in our waterways. Additionally, the engineer who is developing drainage paths and ditches based on 3D mapping from a sUAS is going to prevent large

- scale flooding, which reduces
dam ages to surrounding communities and, in turn, lowers insurance premiums for the country as a whole. In much the same way, planning commissions creating maps and running lines into a new development helps foster community growth and ensures the right amoun t of infrastructure for the community. Finally, the architect designing a new building will be better able to place that building on solid ground and allow it to better fit in the surrounding landscape. This helps ensure the safety of the building while also ensuring the community looks nice.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 59

Referring back to the 4

- D analysis of UAV use, it is clear that the Land Information Services Industry has many applications of data capture that point to the use of UAV systems over manned aircraft because;

 Dull

– Land Information Flights may require a lot of repetition and/or rapid deployment of a data capture device to ensure data is captured at the right time. A government agency looking to quell runoff issues into local lakes and streams from agricultura l fertilizers may want to examine 3D maps and drainage maps that are captured when it is raining or after a heavy rain. The characteristics of these specific flight times will better show the results of water flowage as the flowage is happening or right a fter it happened. This allows for more accurate mapping and a better idea of the real world drainage issues in an area. Having this information leads to better engineering which in turn leads to a healthier environment and community.

 Dangerous

– As the example above shows, the rapid deployment of a sUAS in a rain storm or right after a rain storm could be dangerous for a manned aircraft. Most private pilots who would be flying to take imagery like this would want to avoid weather so as to not have t o be instrument rated or have to operate in non

- visual conditions. Cloud cover may be low during these rain events as well, which may make imagery from a manned aircraft impossible to capture. However, with a sUAS operating below the clouds, you could ca pture this imagery so long as you have the ability to follow VFR requirements. With weather often changing in an instant, a small opening in the clouds in one area might be all you need to fly a sUAS on a mapping mission while manned aircraft is grounded due to the overall weather in the surrounding area.

 Dirty

– Land Information flights by nature may occur in hazardous environments. A lot of the 3D mapping missions conducted in this industry are done in areas of high topography, which can be
hazard ous for manned aircraft at low altitudes.

 Deep

– Once again, sUAS allow for operators to capture high resolution data at low altitudes. This is true in the Land Information Industry as well and low altitude flight can be especially dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in confined areas can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight.

Therefore, the promotion of the public interest described above coupled with the enhanced safety provided by sUAS flights in the Land Information Industry, strongly supports the granting of this petition.

Furthermore, the following previously granted ex emptions point to the FAA’s acceptance of sUAS use in Land Information/Management Industry as being within the public interest.

 Exemption Numbers:

o 11109

o 11204PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 60

o 11286



### Real Estate

The Real Estate Industry was one of the first industries to be granted an Exemption under Section 333.
One of the reasons for this is the obvious benefit the utilization of a small unmanned aircraft can provide for the purp oses of property and home sales. The ability to gain an aerial perspective of a property or house allows potential buyers a way of seeing the property in its entirety. When thinking about traditional real estate listings, there are often a series of phot ographs of the house or property, and its surroundings. However, these pictures are not necessarily congruent, meaning, you, as a buyer, can’t put one picture with the next picture and get a walk around of the property. For example, you see a picture of a gazeebo in the yard. As a perspective buyer you can see that there is a gazeebo but you can’t figure out where it is in relation to everything else on the property because the pictures may not be in sequence or provide an adequate field of view to under stand where a particular feature is located.

Furthermore, aerial cinematography for real estate has existed for many years, however it has previously been accomplished using manned fixed wing or helicopter aircraft. The expense of utilizing
this form of c inematography is extremely costly and prices many realtors and homeowners out of this form of marketing. However, this form of marketing is very valuable and would likely be used by low

budget sellers and agents if it were available.

Additionally, utili zing manned aircraft to capture the type of aerial marketing possible with a sUAS poses significant threats and problems to a community. Obviously a low flying plane or helicopter would supply significant noise and annoyance among neighbors of a home bein g videoed from a plane or helicopter. It is for this reason that there are noise ordinances across the country pertaining to manned aircraft. Obviously, a light

- weight sUAS will produce much less noise than a helicopter or plane operating at low altitude s. Furthermore, there is also substantially less risk associated with a sUAS performing a low

- altitude real estate flight, especially in populated neighborhoods. This is the case because if a manned aircraft goes down in a populated neighborhood there wi ll likely be fatalities or significant damage to the plane and crash site. A sUAS on the other hand would likely cause little damage in the case of a catastrophic crash. Plus, because the sUAS proposed in this petition do not carry combustible fuel, the after

- effect damage is far less as well because there isn’t a risk of a fuel tank exploding or starting on fire.

Furthermore, when looking back at t he 4D’s of UAV Use, it is clear that Real Estate photography and cinematography using small unmanned aircra ft fits the 4D’s.

 Dull

– Real Estate flights for aerial cinematography are a sUAS use

- case marked by repetition
and on

- demand access. More clearly, homes may need to be flown multiple times and on

demand. The key to a good real estate video is that it nicely highlights the features of the real estate being filmed and does so in good lighting conditions. Lighting conditions change constantly and it is best if you can adapt to the lighting and fly at the perfect time in the perfect weather to get the bes t footage. This may mean waiting for 5 or 10 minutes for a cloud to pass through. With a manned aircraft this expensive to do. Plus, with many private pilots rentingPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 61

their aircraft, it would be hard to anticipate what time to rent the plane in order to have it in position at the perfect time.

 Dangerous

– Real Estate flights using manned aircraft would be highly dangerous in comparison to unmanned aircraft. The reason for this is because most flights take place low to the ground, right above houses and many times above highly populated neighborhoods. An accident with a manned aircraft in these conditions could be catastrophic, with potentially many casualties and a lot of property damage. An unmanned craft, like the ones described in this pe tition, would cause much less damage in the case of an accident, as they are small, batt ery powered, and weigh under 10 lbs.

 Dirty

– Commercial UAV flights in the real estate industry can also be dirty, in that they can take place in potentially haza rdous environments. Commercial real estate in particular, in which large factories or plants may be being sold, could pose hazardous environments that are best filmed by sUAS aircraft so as to not expose humans to hazardous waste, gases, or materials for example. Furthermore, decrepit or abandoned buildings that are dangerous to walk through or near, may be best flown using an unm anned aircraft.

 Deep

– Once again, sUAS allow for operators to capture high resolution data at low altitudes.
This is true in the Real Estate Industry as well and low altitude flight can be especially dangerous for manned aircraft. In particular, any high resolution data collection at low altitudes and in confined areas, such as in neighborhoods as an example, can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight.

Finally, becaus e the proposed sUAS contained in this Petition are battery

- powered, they do not release environmentally hazardous emissions. Thus , utilizing these micro

- UAVs in place of manned aircraft benefits the public by promoting a healthier environment.

By granting this Petition for Exemp tion and allowing commercial sUAS flights in the Real Estate Industry, the FAA will be contributing to economic growth by supporting the housing industry and commercial real estate industry, thereby strengthening the economy. Furthermore, all of this can be done by maintaining the safety of the National Airspace and people & property on the ground.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Real Estate Industry as being within the public interest.

 Exemption Numbers:

o 11062

o 11109

o 11112

o 11213PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 62

o 11364



### Search and Rescue

The Search and Rescue Industry is an industry in which small unmanned aircraft will play a vital role moving forward. This industry is known for its rapid resp onse times which are needed in order to save lives. Furthermore, the situations and environments common in this industry require documented visual observance over broad areas. Currently, much of this is done using aerial imaging from a manned
aircraft. The imagery captured on these flights is vital not only when it comes to finding lost people but also in documenting areas that have already been searched. In a searching effort this is important because searchers don’t want to waste time looking in area s that have already been searched. Utilizing a UAV allows for searchers to get an aerial vantage point as well as document areas that have been searched accurately. For instance, a search crew could map the areas of interest using their UAV, stitching th e images they get from the camera and have a georeferenced map of the area in question. In most cases this map is laid over Google Earth and can clearly mark an area that has already been searched. Additionally, becau se the map is georeferenced, the user can pinpoint locations or objects of interest and pull a latitude and longitude for a more detailed search. This is a highly valuable attribute of stitched imagery from a UAV.

In addition, a UAV can provide a superior vantage point for searchers operati ng on the ground. The UAV utilized by the Petitioner offers long

- range, high definition FPV which can be used by a team leader to relay to his ground searchers where to move next and if he sees anything of interest from the air.

The Petitioner seeks exe mption under Section 333 in an effort to gain the right to provide services to the Search and Rescue Industry in order to help in situations where a visual inspection from the air is necessary. The Petitioner seeks this exemption because they believe the use of unmanned aircraft in this industry will provide a public good while maintaining the safety of the National Airspace System.

The Petitioner’s UAV is rapidly deployable meaning it can help in time

- sensitive rescue efforts. Additionally, with its ab ility to take high definition video and pictures while georeferencing all of its images, the Petitioner’s UAV can be a valuable asset to a Search and Rescue Team. Plus, with the aerial perspective this type of UAV can provide, the chances of finding a los t or periled individual increase. Clearly, finding and saving lost people is a public good and one that can be bolstered through the use of

a UAV.

Furthermore, utilizing a UAV for this type of work is a safer alternative when compared to manned
aircraf t. This is the case because often these flights will happen at low altitudes where the risk of collision with ground

- based features, obstacles, or the like are greatest. A manned aircraft is not as well suited for these flying environments because they a re bigger than sUAS, they carry a crew, they are not as maneuverable, and they carry flammable fuel. When you couple this with their higher costs to operate, it is clear that an unmanned craft can provide value in terms of cost savings and enhanced
safet y to the Search and Rescue Industry.PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 63

On top of this, the utilization of sUAS in the Search and Rescue Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– The Search and Rescue Industry is an industry that requires dull flights. Often, especially
with fixed

- wing aircraft, a pilot must fly his plane over a specific area of interest in a very specific and straight line patter n

. This is to ensure complete coverage of the search zone. This causes the pilot to fly the same straight line routes, one next to the other, over and over. The “dullness” of this flight might cause a pilot’s mind to wander which can lead to accidents. Th e sUAS used by the Petitioner however has the ability to utilize preprogrammed flight routes, which can automate the process and allow for safer operations.

 Dangerous

– Aerial Search and Rescue Imagery is often captured at low altitudes, which is very
d angerous airspace for large, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Search and Rescue flights using manned aircraft are more dangerous than if the same manned aircraft were operating a t higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash as it weighs significantly less and doesn’t carry a crew or flamma ble fuel.

 Dirty

– Aerial Search and Rescue Imagery is sometimes captured in hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is important to consider that mistakes can happen in unpredictable situations. For instance, if a UAV is being used to provide a live

- feed view of a rescue situation, there may be a host of unpredictable hazards such as rock

- falls, crashing waves, avalanches, or the like. In each of these situations it would be better to have an expendable UAV system rather than a manned aircraft with lives onboard.

 Deep

– Some Search and Rescue imaging may require capabilities that only an unmanned aircraft can perform, such a s flying in close proximity to natural features or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft would be required.

Ad ditionally, the following previously granted exemption points to the FAA’s acceptance of sUAS use in the Search and Rescue Industry as being within the public interest.

 Exemption Number:

o 11419


## Regulations Requested for ExemptionPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 64



### Appendix 1: Regulations Requested for Exemption

– List

https://drive.google.com/file/d/0B8sknt2zpxhMajc4dHA2bjE4bjg/view?usp=sharing



## Exhibit List

Exhibit 1: Manny Rodriguez Operations Manual

https://drive.google.com/file/d/0B8sknt2zpxhMcFFqOUtBX0liMzQ/view?usp=sharing



### Exhibit 2: Manny Rodriguez Logbook Example

Below is a logbook example from the app that is running the Flight Logs for the Petitioner’s aircraft. The specific flight logs pictured are just an example and not specific to the Petitioner’s prior flights. In addition to the logbook, please see the linked video ( https://www.youtube.com/watch?v=4afE

- rd6xoY ) that shows how the flight logs can be played back utilizing the same logging app for each flight.



### Exhibit 3: Manny Rodriguez Visual Observer Training Procedures & Guide

Visual Observer Training Procedures

https://drive.google.com/open?id=0B8sknt2zpxhMNFllQVJZdHVsQ0EPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 65



### Visual Observer Training Guide

https://drive.google.com/open?id=0B8sknt2zpxhMbElBZTcwUi02aHM



### Exhibit 4: Manny Rodriguez Pilot In Command Training Guide

Pilot In Command Training P rocedures

https://drive.google.com/open?id=0B8sknt2zpxhMNFllQVJZdHVsQ0E



### Pilot in Command Training Guide

https://drive.google.com/open?id=0B8sknt2zpxhMREF0OHZLZ25Jc2M



### Exhibit 5: DJI Phantom 3 Professional

http://www.dji.com/product/phantom

- 3



### Exhibit 6: DJI Phantom 3 Professional User Manual

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2 _en.pdf



### Exhibit 7: DJI Phantom 3 Professional Quick Start Guide

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_ 3_Professional_Quick_Start_Guide_en.pdf



### Exhibit 8: DJI Phantom 3 Professional Features

http://www.dji.com/product/phantom

- 3/featurePETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 66



### Exhibit 9: DJI Phantom 3 Professional Specifications

http://www.dji.com/product/phantom

- 3/spec



### Exhibit 1 0: DJI Phantom 3 Professional Flight Controller System

http://www.dji.com/product/ phantom

- 3/flight

- system



### Exhibit 1 1: DJI Phantom 3 Professional Smart Battery Manual

http://download.dji

innovations.com/downloa ds/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 1 2: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

http://download.dji

- innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf



### Exhibit 1 3: DJI Inspire 1

http://www.dji.com/product/inspire

- 1



### Exhibit 1 4: DJI Inspire 1 User Manual

http://download.dj i

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf



### Exhibit 1 5: DJI Inspire 1 Quick Start Guide

http://download.dji

- innov ations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_en.pdf



### Exhibit 1 6: DJI Inspire 1 FeaturesPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 67

http://www.dji.com/product/inspire

- 1/feature



### Exhibit 1 7: DJI Inspire 1 Specifications

http://www.dji.com/product/inspire

- 1/spec



### Exhibit 1 8: DJI Inspire 1 Flight Controller System

http://www.dji.com/product/inspire

- 1/flight

- control



### Exhibit 1 9: DJI Inspire 1 Smart Battery Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



### Exhibit 2 0: DJI Matrice 100

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100



### Exhibit 2 1: DJI Matrice 100 User Manual

http://download.dji

- innovations.com/downloads/d ev/Matrice/en/M100_User_Manual_v1.0_en.pdf



### Exhibit 22 : DJI Matrice 100 Features

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/features



### Exhibit 23 : DJI Ma trice 100 Specifications

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/specsPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 6 8



### Exhibit 24 : DJI Matrice 100 Smart Battery Manual

http://download.dji

innovations.com/downloads/dev/Matrice/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



## References

1.) 

### NTSB. Michael P. Huerta, Adminis trator, Federal Aviation Administration v. Raphael

Pirker . Washington, DC: National Transportation Safety Board, 17 Nov. 2014.
PDF. Aircraft Definition.

2.) 

### Administration, Federal Aviation. "FAA Streamlines UAS COAs for Section 333." FAA.gov

.

Federal Aviation Administration, 24 Mar. 2015. Web. 5 Nov. 2015.

3.) 

### Administration, Federal Aviation. "Section 333 Petition Guidance & Checklist." (n.d.): n.

pag. FAA.gov . Federal Aviation Administration. Web. Conditions for a successful Exemption.

4.) 

### Watts, Adam C., Vincent G. Ambrosia, and Everett A. Hinkley. Unmanned Aircraft

Systems in Remote Sensing and Scientific Research: Classification and Consideration of Use . Basel, Switzerland:

w ww.mdpi.com/journal/remotesensing, 8 June 2012. PDF. "D's" of Unmanned
Aircraft Use.

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### SKYbrary. "Unmanned Aircraft Systems."

- SKYbrary Aviation Safety. N.p., n.d. Web.

20 July 2015.

6.) 

### Administration, Federal Aviation. "Public Guidance for Petitions for Exemption under

Section 333." FAA.gov . Federal Av iation Administration, n.d. Web.

7.) 

### "FAA Summary Grants Speed UAS Exemptions." FAA Summary Grants Speed UAS

Exemptions. Federal Aviation Administration, n.d. Web. 20 July 2015. Permitting Recreational and Sport Pilot Certificates.

8.) 

### FAR Part 91

- Basic VFR Weather Minimums, Code of Federal R egulations § 91.155

(2004). Print.

9.) 

### Administration, Transportation Security. "Vetting of Airmen Certificates and General

Aviation Airport Access and Security Procedures." Department of HomelandPETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 69 

### Security . Office of Inspector General, 7 July 2011. Web. 5 Nov. 2015.

10.) 

### MacPherson, Rebecca B. "U.S. DOT / FAA

- Office of the Chief Counsel." Letter to Mr.

Timothy John Gilbert. 25 Feb. 2011. MS. 800 Independence Ave. S.W., Washington, DC, Maryland. Clarification on "Furtherance of a business."

11.) 

### Federal Aviation Administration . "Exemption No. 11062A Regulatory Docket No. FAA

2014

- 0352." Department of T ransportation, 23 July 2015. PDF

.

12.) 

### Jensen, Warren, PhD. Ground

- Based Visual Observer/Crewmember Training for UAS

.

New York, NY: Slideserve.com, 9 July 2008. PPT. Visual Observer and Pilot In Command Training Guidance and Format.

13.) 

### Schoepp, Brenda. "Brenda Schoepp

- International Mentor. Inspirational Speaker.

Creative Writer." Brenda Schoepp. Brenda Schoepp, 2012. Web. 20 July 2015. Quote.

14.) 

### Organization, Food And Agricultural. Global Agriculture Towards 2050 . Rome, Italy:

Agricultural Development Economics Division, 13 Oct. 2009. PDF. UN Projections Global Food Demand in 2050.

15.) 

### “University of Wisconsin

– Whitewater 2014 Annual Report.” Enac tus Scouting Forward

.

Whitewater, WI: UW

- Whitewater Enactus, Feb. 2014. PRINT.

16.) 

### Vilsack, TOM. 2012 Census of Agriculture . Rep. Washington, D.C.: United States

Department of Agriculture, 2014. PDF.

17.) 

### "Olympic Medalists among 10 Dead as Reality TV Choppers Collide." NBC News . NBC,

n.d. Web. 20 July 2015.

18.) 

### "Deaths From Aerial Lifts." ELCOSH : . N.p., n.d. Web. 20 July 2015.

19.) 

### Day, Liz. "Feds to Look Harder at Cell Carriers When Tower Climbers Die." Top Stories

RSS . Propublica, 01 Apr. 2014. Web. 20 July 2015.

20.) 

### Robb, Gary C. Helicopter Crash Litigation . Tucson, AZ: Lawyers & Judges Pub., 2010.

Print.


## Exemption References

Exemption # 11467

Exemption # 11905PETITIONER

– Manny Rodriguez DOCUMENT PREPARER

– DMZ Marketing, LLC. 70



### Exemption # 11797

Exemption # 12031

Exemption # 11865

Exemption # 11364

Exemption # 11587

Exemption # 11857

Exemption # 11293

Exemption # 11814

Exemption # 11540

Exemption # 11345