Date August 17, 2015

Petitioner
Name Joel Williams

UAS Operating Parameters
The petitioner states that he will abide by the following additional operating co nditions under this exemption:

• operate his UAS below 4 00 feet and within a radius distance of 1000 feet from the controller to both aid in direct line of sight visual observation;

• maintain a safe stand

- off distance to structures (30 feet) and non

- particip ating observers (150 feet).

• operate the UAS for no more than 15 minutes per flight;

• operate his UAS only within visual line of sight (VLOS) of himself and/or visual observer (VO);

• land his UAS prior to the consumption of 80% of rated battery capacity as m easured by onboard sensors;

• enable automated safety features to alert the PIC to low battery levels beginning at 60% consumption and initiating automated landing procedures at 7 0 % consumption;

• in stall and calibrate a global positioning system (GPS) in accordance with the flight controller manufacturer ’ s recommendations to enable flight safety feature s whereby the UA will automatically hover and then slowly descend and land if communication with the remote control pilot is lost;

• conduct all operations under his own personal and flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress

– Remain Back 150 feet”) contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance his safety protocols;

• contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information;

• always obtain all necessary permissions prior to operation; and

• have proce dures in place to abort flights in the event of safety breaches or potential danger.Petitioner states that § 91.7(a) prohibits the operation of an aircraft without an airworthiness

certificate. The petitioner asserts that since there is currently no cert ificate applicable to his operation, this regulation is inapplicable. Petitioner states that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board his aircraft and given its size, this reg ulation is inapplicable. He further indicates an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station.
Petitioner states that § 91.119 prescribes safe altitudes for the operation of civil aircraft, b ut that it allows helicopters to be operated at lower altitudes in certain conditions. Petitioner states he will not operate his UAS above the altitude of 4 00 feet above ground level (AGL) , and will also only operate in safe areas away fro m the public and traffic, thus providing a level of safety at least equivalent to those in rela tion to minimum safe altitudes. The petitioner asserts that given the size, weight, maneuverability, and speed of his UAS, an equivalent or higher level of safety will be achieve d.
Petitioner indicates that § 91.121 Altimeter settings is inapplicable since he UAS utilizes electronic GPS with a barometric sensor.