Noah H. Greenlaw

Get Droned 13 Elm St E Hampden, ME 04444
October 1 st, 2015 US Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a) and (b) To whom it may concern: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Noah H Greenlaw, DBA Get Droned, hereby applies for an exemption from the listed Federal Aviation Regulations to allow commercial operation of a small UAS, 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, for all operators of small Unmanned Aerial Systems (UAS) working for WASP. Commercial operation small UAS, as described herein, which are equipped with cameras and sensors, would operate in the following manner:
1. Aerial photography and/or video for public an d/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, and cinematography. 3. Aerial inspe ction/photography of residential/commercial structures under contract with the owners or local government authority. 4. Ariel video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disast er only when local authorities or government has requested it by contract or donation. As described fully below, the requested exemption would permit the op eration of small UAS under contro lled conditions in the NAS that would be a) limited b)controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of the exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Admini strator’s) responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system.” The name, phone, email and address of the applicant:
Name: Noah H Greenlaw Phone: (207)319

-4383 E

- mail: noah.grenelaw@gmail.comAddress: 13 Elm St E, Hampden, ME 04444

Regulations from which the exemption is requested: 14 CFR 21 subpart H; 14 CFR 45.23(b) 14 CFR 61.113(a) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) and (b) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) and (2) 14 CFR 91.417(a) and (b) The small UAS’s I will be using are multi

- rotor craft weighing no more than 55lbs. including payload. Under normal conditions they operate at speeds of no more than 45 Mph or 39 Knots and have the ability to hover and move along a vertical and horizontal plane simultaneously. They will operate within line of sight and by the exempted persons only obeying all other local and federal laws. Given the small size of the small UAS and the controlled environment provided the proposed operations will adhere to the Reform Act’s safety requirements. The approval of the application presents no national security issues. Regarding t he level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emission and noise, the grant of the requested exemption is in the public interest. Accordingly the appl icant requests that the FAA grant the requested exemption within 120 days of submission with minimum delay
**AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY** The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitation and condition to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Op erations Manual (FOM) include:

1. The small UAS total weight, with payload, will be less than 55lbs. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 20% battery power reserve or 20 minutes of flight time whichever occurs first. 4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 100 feet above an elevated platform from which filmi ng is planned. 5. Minimum crew for each operation will consist of the small UAS Pilot in Command (PIC), the Visual Observer (VO) when needed and may include but not limited to a Camera Operator. 6. A briefing will be performed regarding the planned small UAS ope rations prior to each day’s flight consisting of all the days’ production activities.7. The PIC will obtain verbal/written consent of all persons involved with the planned operation and ensure that only the consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advanced permission or direction of the FSDO, operations at closer range may be approved. 8. The PIC and VO will have been trained in operation of small UAS and/or Camera. 9. The PIC and VO will be able to communicate by voice, radio and/or text at all time. 10. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies when needed. 11. If the small UAS loses communications or loses GPS signal, the small UAS will have the capability to return to a pre

- determined location within a design ated location and land autonomously. 12. The small UAS will have the capability to abort a flight in case of unpredicted obstacles, weather or emergencies. **14 C.F.R. Part 21, Subpart H: Airworthines s Certificates 14 C.F.R.**  **§91.203(a)(1)** Subpart H, entitled A irworthiness Certificates, establishes the procedural requirement for the issuance of airworthiness certificates as required by FAR 91.203(a)(1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exe mption from Part 21 Subpart H meets the requirements of an equivalent level of safety under part 11 and Sections 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airwort h iness certificate, upon consideration of th e size, weight, speed, operational capability, and proximity to airports and populated areas of the particular small UAS. In all cases, an analysis of these criteria demonstrates that the small UAS operated without an airwo rthiness certificate, in the rest ricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft(fixed wing or rotorcraft ) operating with an airworthiness certificate without the restriction and conditions proposed. The small UAS to be operated hereunder is less tha n 55lbs. fully loaded, carries neither a pilot nor passengers, carriers no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unli ke other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancement provide a greater degree of safety to the public an d property owners than conventional operation conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security p o sed by the sm all UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.
**14 C.F.R. §45.23(b)**  **: Making of the Aircraft.**  The regulation requires: When mar ks include the only the Roman Capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certified aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, 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.Even though the small UAS will have no airworthiness certificate, an exemption may be needed as the

small UAS will have no entrance to the cabin, cockpit, or pilot station on which the word “experimental” can be placed. Given the size of the small UAS, two

- inch lettering will be impossible. The wo rd “experimental will be placed on the fuselage in compliance with 45.29 (f). The equivalent level of safety will be provided by having the small UAS marked on its fuselage as required by 45.29(f) where the pilot, observer and others working with the small UAS will see the identification of the small UAS as “experimental.”
**14 C.F.R. §**  **61.113 (**  **a ):**  **Private Pilot Privileges and Limitations: Pilot in Command.** Pursuant to 14 CFR 61.113(a), no person who holds a private pilot certificate may act as a pilot ion command of an aircraft that is carrying passengers or property for compensation or hire. Our small UAS do not carry any pilots or passengers nor p roperty therefore I am seeking an exemption to 14 CFR 61.113(a) . Although helpful a pilot’s license will not e nsure remote control piloting skills. The risks attendant to the operation of small UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will equate to t he safe operation of the small UAS.
**14 C.F.R. §** **91.7 (**  **a ):**  **Civil Aircraft Airworthiness.** The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for dete rmining airworthiness. Given the size of the aircraft for maintenance and use of safety checklists prior to each flight an equivalent level of safety will be provided.
**14 C.F.R. §** **91.9 (**  **b )**  **(2) :**  **Civil Aircraft Flight Manual in the Aircraft.** Section 91.9(b)( 2) provides: No person may operate a U.S. registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by 21.5 of this chapter, unless there is available in the aircraft a current approved airplane or rotorcraft flight manual, approved manual material, marking and placards, or any combination thereof. The small UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but beca use there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the small UAS will have immediate access to it.
**14 C.F.R.**  **§ 91.103: Preflight Action.**  This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be nee ded. The OPERATOR will take will take all actions including reviewing weather, kp

- index, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.
**14 C.F.R. §91.109: Flight Instruction.** Section 91.103 provides that 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. Small UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. An e quivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.
**14 C.F.R. §91.1**  **19: Minimum Safe Altitudes.** Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies wit h any route or altitudes prescribed for helicopters by the FAA. As this exemption is for small UAS that is a helicopter and the exem ption requests authority to operate at altitudes up to 400 feet AGL, or not more than 100 feet above an elevated platform from which the filming is planned, an exemption may be needed to allow such operations. As set forth herein, the small UAS will never operate at higher than 400 feet AGL with the exception that in some circumstances where the small UAS will is used to survey or photograph a structure whose height exceeds 400 feet AGL, the small UAS will not be operated more than 100 feet above the highest point on the structure. It will however be operated in a restricted area with a security perimeter, where buildings and pe ople will not be exposed to operations with their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the small UAS as well as the location where it is operated. No flight will be taken without the permiss ion of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. proposed herein and the lack of flammable fuel and risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In additi on, the low altitude operation of the small UAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119.
**14 C.F.R. §91.1**  **21: Altimeter Settings.** This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “... to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the small UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitud e of the launch site shown on the GPS altitude indicator before flight.
**14 C.F.R. §91.1**  **51(a): Fuel Requirements for Flight in VFR Conditions** Section 91.151(a) prohibits an individual from beginning “ a flight in an airplane under VFR conditions unless (co nsidering 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.” The battery powering the small UAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 C.F.R. §91.1 51(a), small UAS flights would be limited to 0 minutes in length. Given the limita tions of theUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a

longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from C.F.R. §91.151(a ) falls within the scope of prior exem ptions. Operating the small UAS in a tig htly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that C.F.R. §91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting the small UAS flights to 0 minutes would greatly reduce the utility for which the exemption will be granted. Ap plicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 20% battery power remaining

- whichever happens first. This restriction would be more than adequate to return the small UAS to its planned landing zone from anywhere in its limited operating area.
**14 C.F.R. §91.**  **203(a) and (b): Carrying Civil Aircraft Certification and Registration** The regulation provides in pertinent part: (a) Except as provided in §91. 715, no person may operate a civil aircraft unless it has within the following: (1) An appropriate and current airworthiness certificate... (b) No person may operate a civil aircraft unless the airwort h iness certificate required by paragraph (a) of this section or a special flight authorization issued under §91. 715 is displayed at the cabin or cockpit entrance so that it is legible to passenger and crew. The small UAS fully loaded weighs no more than 55lbs. and is operated without an inboard pilot. As such, there is no ability or place to carry certificatio n and registration documents or to display them on the small UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the small UAS will have immediate access to them; to the extent t hey are applicable to the small UAS.
**14 C.F.R. §91.**  **405(a); 407(a)(1); 409(a)(2); 417(a)&(b): Maintenance Inspections.** These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply to only aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the small UAS can land immediately and will be operatin g no higher than 400 feet AGL. The operator will ensure that the small UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with th e aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the small UAS Manufacture’s Manual, as referenced in the Aircraft Operations Manual ( AOM). As provided in the FOM, the operator will ensure that the small UAS is in working order prior to initiating flight and perform required maintenance needed.**Small UAS Information** 

Small UAS’s to be used are as follows but not limited to providing they are within the scope of the exemption granted by the FAA:
1. 3DRobotics Solo Weight: (battery & propellers included)

– 3.9lbs. Hover Accuracy

– Vertical: +/

- 1.64ft.

Horizontal: +/

- 1.64ft. Max Yaw Angular Velocity: 200°/s Max Tilt Angle: 35° Max Ascent Speed: 16ft/s Max Descent Speed: 8ft/s Max Flight Speed: 55mph 2. 3DR Solo Battery Lithium polymer, 5200mAh, 14.8vdc battery 3. 3DR Solo Gimbal Controllable Range: Pitch: 90°

- 0° Stabilization: 3

- axis (pitch, roll, yaw) 4. GoPro Hero 4

– Black Operating Temperature: 32° F

- 104° F Sensor Size: 1/2.3 Effective Pixels: 12M Resolution : 4000x3000 Recording:

- UHD: 3840x2160p 24/25/30 fps

- FHD: 1920x1080p 24/25/30/60/120 fps

- HD: 128 0x720p 24/25/30/60/120/240 fps Recording FOV: 178°

- 100° 5. 3DR Solo Controller

- Operating Frequency: 2.400GHz

– 2.483GHz

- Communication Distance (unobstructed)

– FCC Compliance: 2400ft.

- Receiver Sensitivity (1%PER): 101dbm +/

- 2dbm

- Transmitter Power

– FCC Compliance: 20dbm
Conclusion Thank you for consideration of these exemptions. Sincerely, Noah H. Greenlaw Owner/Operator Get Droned