Sport Aviation Center LLC Exemption Request Section 333 Page 1 January 2 1 , 2016

To: U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012



### Operators Name and address :

Paul Hamilton Sport Aviation Center LLC

711 S. Carson Street Carson City, NV 89701

Phone 775.772.8232 Paul@SportAviationCenter.com



### PIC Operators background and experience

Paul Hamilton (FAA pilot # 3051445) holds the FAA ratings of P rivate Pilot, Flight Instructor with a Sport Rating (CFIS), Light Sport Repairman Maintenance (LSRM) and is a Designated Pilot Examiner (DPE )

. He owns and o perates an FBO at the Carson City Airport CXP specializing in light

- sport aircraft (LSA) instructio n. H e supervises other CFI's teaching Sport

and P rivate pilot certificates in LSA. http://sportaviationcenter.com/ Additionally, Paul owns and operates a production company specializing in light sport
instruction training materials including DVD's, book's, CD's and on line training. http://pilot

- stores.com/

This extensive experience with aircraft operations, training and accident free operations will

enh ance the UAS operations in this region and be a great step for overall UAS safety and operations in the public interest

.

Paul Hamilton will be directly responsible for all operation s of the UAS.

Any t raining will be done similar to dual aircraft training where Paul Hamilton CFI S will be operating the UAS directly or supervising the student if the control box is handed over to the

student. The "release and return" command will be used to :
1. allow the UAS to automatically hover when t he controls are released and

2. hand the controls box back to Paul Hamilton This is a "similar" standardized procedure to the manned aircraft controls exchange.Sport Aviation Center LLC Exemption Request Section 333 Page 2 

### Proposed Operations
Sport Aviation Center requests a broad range of services including but not limited to UAS flight training, GA/ UAS education, photography, videogra phy, surveys

, inspections,
search/rescue and /or demonstration flights

.

• All operations will comply with current local, state and federal requirements and regulations.

• All operations will follow the current UAS manufacturer's checklists, maintenance procedures, operating limitations and operational procedures (provided below)

.

• All operations will be similar to manne d aircraft with TFR, NOTAMS. C urrently use Foreflight a nd the new FAA service B4UFLY will be used additionally for UAS operations.

• All operations will comply with Title 14 CFR Part 91 same as manned operations for compliance and safety.

• All operations w ill exercise common sense with safety as number one priority

.

• All operations will comply with operating limitation s as specified in the FAA 333 Exemption and a COA

.

• All operations would comply and stay up to date with the FAA requirements/regulations at http://www.faa.gov/uas/



### Make, M odel and Description of UAS

Make

- DJI

, Model

- Phantom 3 Advanced . W eigh with battery, camera and prop ellers 2.8 pounds

. Diagonal size including propellers 23.2 inches

. Max speed approx 33MPH

.

This is a modern state of the art UAS with GPS and optical assisted hover with " hands off the

controls " and one button return to home. The intelligent battery and integrated software automatically returns t o the UAV home when the battery gets to 25% capacity . Control panel has a visual display of what the camera sees plus a map of where the UAS is compared to

the controller and overall position

.

Th is UAS has a built

- in capability to limit the height it flies above the ground, to limit th e radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. The Phantom 3 Advanced has the failsafe function of the autopilot system, which means when the communication between the M ain Controller and the transmitter is disconnected, the outputs of all command sticks from controller will go to the center position. If the GPS signal is good enough, the system will automatically trigger Return to Home and will land safely. Overall, t hi s UAS has numerous safety features which

add UAS safety and operations in the public interest.

To not duplicate current inform ation that can change and up date over time, see http://www.dji.com/product/phantom

- 3

- adv for basic information on the UAS and http://www.dji.com/product/phantom

- 3

- adv/info#downloads for the current flight manual

which will be us ed for the up dated manufacturer's checklists, maintenance procedures, operating limitations

, operational procedures and specific UAS specifications

.Sport Aviation Center LLC Exemption Request Section 333 Page 3 

### Specific applicable regulations from which relief is required (CFRs);
The petitioner requests relief from the following regulations from which the exemption is requested:

14 C.F.R. § 91.109 (a) Flight Instruction For UAS flight instruction, dual controls is not needed because the default hands off is the

hover mode or t he return to h ome can be used while the single control box is exchanged
between the instructor and the UAS student similar to the controls exchange process for flight

instruction in manned aircraft which provides an equivalent level of safety for dual cont rols during instruction.

14 C.F.R. § 91.119 Minimum safe altitudes Since the typical maximum altitude is 400 feet AGL for UAS, the UAS will operate at lower altitudes and therefore relief from minimum safe altitudes is requested. Any flight will be

conducted without undue hazard to persons or property on the surfa ce providing an equivalent level of safety.

14 C.F.R. § 91.121 Altimeter Settings UAS does not have a barometric altimeter, but rather GPS altitude and an optical AGL sensor. Therefore, and equivalent level of safety will be provided with the calculated GPS

MSL/AGL with the GPS and optical sensors.

14 C.F.R. § 91.151 Fuel Requirements for flights in VFR conditions The batteries powering Sport Aviation C enter LLC ’s Pha ntom 3 UAS’s provide approximately

2 3 minutes of powered flight. Therefore, it cannot meet 30 minutes reserve fuel requirement

. However, the limitations o f the UAS's flight area to line of site plus a built in 25% battery capacity "return to home" safety f eature in the software provide equivalent safety margin based on a reserve amount of battery life . This safety feature is more than adequate to return the UAS safely to its planned landing zone even in the event of a headwind or an unexpected

occurrence.

14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b) Maintenance , Inspection and Record Keeping These regulations refer to Part 43 which only apply to aircraft with an airwor thiness certificate, which the UAS does not have. An equivalent leve l of safety will be achieved because maintenance and inspections will be performed in accordance with FAA, NTSB, and

AFS

- 80 best practices. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed

. If mechanical issues arise, the UAS's simplicity for maintenance, and the fact that flight operations will only take place close proximity areas for limited periods of time during daylight hours, creates less ri sk than that associated with conventional manned aircraft

.Sport Aviation Center LLC Exemption Request Section 333 Page 4 

### Summary

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload an d maximum flight time of only 23 minutes, this offers little or no risk to national security and provides sa fety and operations in the public interest.

Sport Aviation Center LLC ’s singular vision is to enhance safety of UAS operations in the NAS while reducing risk to the general public and property owners.

The DJI UAS, weighing less than 25 pounds and powe red by batteries, eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on bard. The UAS is transported to the designated mission area and set up there. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requi rements of several regulations and allowing commercial operations. These lightweight UAS’s operate

at slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional operations conducted with fixed wing air craft or helicopters.

If additional information is required, or if you have any questions regarding this Petition for Exemption, please contact the undersigned at:

With Best Regards,

Paul Hamilton CFI, DPE, LSRM

Sport Aviation Center LLC

Phone (775) 772

- 8232

Paul@SportAviationCenter.com