February 10, 2015

Lawrence Puchalski

46 Kosinski Rd

Covington Township, PA 18444

Cell 570-499-2397

Office 570-842-0361

Email: larry@puchalskiinc.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

1) Phantom 2 Vision+ User Manual V1.04

2) Phantom 2 Vision Plus Quick Start Guide

3) Phantom 2 Vision Pilot Training Guide

4) Phantom 2 Vision Release Notes

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481

in the matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in

the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355

in the matter of the petition of FLYING CAM INC

Dear FAA,

In accordance with the FAA’s Guidelines for Submitting a Petition for

Exemption under section 333 of the FAA Modernization and Reform Act

of 2012, I, Lawrence Puchalski, request exemption from the following sections

of Title 14, Code of Federal Regulations §§

61.113(a). 61.113(b). 91.119(c). 91.121. 91.151(a). 91.405(a).

91.407(a)(1). 91.409

(a)(1). 91.409(a)(2). 91.417(a) & (b).

In order to operate small unmanned aircraft systems (UAS) commercially in

airspace regulated by the Federal Aviation Administration (FAA) for the purposes

of aerial photography, structural inspections of bridges, pipelines, well and cell

towers, real estate marketing and surveys and other flight operations that could
be performed safely and more cost effectively with the use of small UAS at low

altitude within the U.S. national airspace system as compared to a manned

aircraft. Operations will be performed only at the request of and with the

authorization and permission of clients or their authorized agents in order to

facilitate commerce and raise awareness of the beneficial uses of small

unmanned air systems. So long as such operations are conducted within and

under the conditions outlined herein or as may be established by the FAA as

required by Section 333. The conditions identified and proposed by, Lawrence

Puchalski, are drawn from references 13.

The FARs

I, Lawrence Puchalski, request exemption from the above mentioned FARs for

the following reasons.

61.113(a) & (b). I, Lawrence Puchalski, request relief in order to facilitate the

utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots

operating under this exemption would be required to comply with any conditions

as set forth and in a similar fashion to the previously granted exemptions. A

Visual Observer will be used at all times while under this requested exemption.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU),

operations conducted closer than 500 feet to the ground may require that the

UA be operated closer than 500 feet to essential persons, or objects that would

not be possible without additional relief. The petitioner requests modification,

waiver or exemption and clarification concerning the terms “congested areas”

and “densely populated”. I, Lawrence Puchalski, request waiver for this

condition to allow reasonable and responsible operations with safety as my main

concern in areas of subdivisions and neighborhoods if required.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is

inapplicable since the UAS does not have an altimeter and instead utilizes

electronic GPS with a barometric sensor for altitude information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION

SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at

less than the prescribed minimums, including Exemption Nos. 2689, 5745, and

10650. In addition, similar UAS specific relief has been granted in Exemption

Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides

battery power remaining in percent to the PIC. The UA batteries provide

approximately 25 minutes of powered flight. Information provided in the

operating documents discusses procedures regarding remaining battery power

management. Those documents contain a condition in which the PIC will initiate

a landing procedure when battery remaining reaches a specified level. Given the

limitations on proposed operations and the location of those proposed
operations, The FAA found that a reduced minimum power reserve for flight in

daytime VFR conditions was reasonable.

91.405(a). 91.407(a)(1). 91.409 (a)(1) & (2). 91.417(a) & (b) As

discussed in Exemption 11138 (DOUGLAS TRUDEAU), I, Lawrence Puchalski,

propose to inspect and ensure that the UAS is in a condition for safe flight in

accordance with the operating documents. The FAA found that adherence to the

petitioner’s operating documents and the conditions and limitations specified,

describing the requirements for maintenance, inspection, and recordkeeping,

were sufficient to ensure that safety would not be adversely affected.

The UAS

The DJI Phantom 2 vision plus is a highly successful consumer grade small

rotorcraft in the quadcopter configuration with an advertised weight of less than

44 ounces (1242g) designed primarily to carry aloft a high definition camera. It

has an advertised maximum speed of less than 30 knots (15m/s) and a

maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by

four electric motors with a distance between motors of less than 14 inches

(350mm) It utilizes an internal inertial measuring unit (IMU) with integrated

barometric sensor augmented with global positioning system (GPS) to maintain

its geospatial orientation and position. It is controlled primarily through an FCC

certified radio control (RC) unit. Real time video and telemetry information is

transmitted back to a ground control station allowing the operator and/or PIC to

monitor battery level, GPS signal strength, altitude (AGL), distance from PIC,

camera imagery, and control camera angle. It has fail safe modes of operation

for either loss of RC or GPS signal. Altitude can be limited by the onboard flight

controller and maximum altitude can be preprogrammed by the PIC. Battery life

limits flight times to approximately 25 minutes. The onboard flight controller will

warn the pilot via telemetry and external lighting cues before reaching a low

battery state. An automatic termination of flight and landing will be initiated

when the battery reaches a predetermined low state. It is anticipated that flights

will usually last less than 10 minutes. More information is available in attachment

1.

Risk mitigation

I, Lawrence Puchalski, have reviewed FAA exemptions reference’s 13

Conditions and Limitations section and believe that the procedures specified

therein are reasonable and will be utilized in order to manage and mitigate risk

and ensure public safety.

A preflight checklist will be developed and employed to ensure that the UAS’s

airworthiness will be verified before launch. Airworthiness will be maintained by

performance of routine inspections before each flight, maintaining flight and

maintenance logs to record time on failure prone components.
I, Lawrence Puchalski, request that in a manner similar to reference 3, be

allowed to operate within 5 miles of an airport provided that.

“The UA may not operate in Class B, C, or D airspace without

written approval from the FAA. The UA may not operate within 5

nautical miles of the geographic center of a non towered airport as

denoted on a current FAA published aeronautical chart unless a letter

of agreement with that airport’s management is obtained, and the

operation is conducted in accordance with a NOTAM as required by the

operator’s COA. The letter of agreement with the airport management

must be made available to the Administrator upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but I am

requesting a mechanism to facilitate such activities without requesting a new

and separate exemption(s) should the need arise. Operations within class B

airspace are not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned

aircraft of greater proportions, carrying a crew and flammable fuel.

In regards to performing inspections of bridges, towers, and natural gas

pipelines the UAS will minimize the risk to persons attempting to climb these

structures and photograph problem areas. It will provide a way for companies to

have their engineers review photographs and provide additional safety to the

general public in regards to towers failing or natural gas pipelines having

structural issues. Many of the natural gas pipelines in our area travel in areas

that are hard to reach by vehicle or foot and if an area is suspected of having

problems the UAS can reach it to make an assessment easier and safer.

I, Lawrence Puchalski, will also make the UAS and myself available to local

volunteer organizations (for no charge) such as fire departments, local law

enforcement, etc., to perform search and rescue operations, or other similar

events as directed by authorities.

In addition the use of the UAS in order to facilitate commerce could lead to

economic growth. Operations for this petition will enable service for property

owners or their designees seeking an enhanced perspective for characteristics,

amenities, and benefits of their desired photographic subjects that cannot be

displayed through ground level photography. Aerial photography is a valuable
marketing tool that can lead to increased commerce and enhance my personal

photography.

A visual observer will be utilized at all times that the UAS is performing duties for

compensation and the PIC will hold a Private Pilots license.

Liability insurance will be obtained commensurate with the granting of this

request for exemption.

Flight data including UAS flight time, Control Unit operation time, incident, and

details will be recorded for each flight and made available to the FAA at any time

needed.

Any deviations from normal operations will also be recorded and made available

to FAA.

Conclusion

I, Lawrence Puchalski, am requesting this exemption for the purposes of aerial

photography of real estate, bridge inspections, land surveying, pipeline

inspections, tower inspections, and other flight operations.

The reason for such a general and broad based request is that I, Lawrence

Puchalski, wish to utilize a business strategy in order to capitalize on

opportunities as they may arise in the future without the long turnaround time

associated with additional exemptions.

My business model is based on the idea of offering small UAS services to

individuals or companies who wish to employ these services as a safe,

effective, and legal option to enhance their business or prevent structural

disasters that may influence the general public or individuals.

My own research shows an upward demand for these services that currently

exists in the real estate market, natural gas market and other markets are just

beginning to realize the need for such services.

Several people are offering services such as the above in my area but I have

refrained for pursuing commercial use of my UAS until I can properly be

authorized by the FAA.

I have been a licensed Private Pilot since January, 1975 License # 3788936, hold

a Class III Medical Certificate, and have flown countless hours in fixed wing

aircraft and have flown Radio Controlled Aircraft since 1985. I am familiar with

aircraft preflight and have built and repaired Radio Controlled Aircraft in the

past. I have extensive experience with a UAS and extensive experience as a

photographer. I am also a licensed Pennsylvania Real Estate Sales Person since

1986 License # RS151675-A and feel that having this Exemption will help

enhance my ability to provide superior customer satisfaction.