Aerial PIC llc Jeff Webbe, Owner & Operator 17941 W. Jojoba Rd., Goodyear, AZ 85338 jjwebbe@gmail.com August 13, 2015

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

Re: Docket ID FAA

- 2015

- 1763

- 0001 Exemption Request Section 333 of the FAA FMRA and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

In a letter dated July 30, 2015, from Brittany Newton, Program Analyst, Airmen and Airspace Rules Division of the FAA, I was informed that my request for exemption from Section 333 /Part 11 of the FARs (Docket ID FAA

- 2015

- 1763

- 0001) co uld not be processed without further information. This submission is an addendum to my original petition for exemption in order to provide , in addition to documents previously filed in the public docket, the following requested information :

1) Reasons why gr anting this request for exemption would be in the public interest and would not adversely affect public safety 2) Additional information available to support this request 3) A summary of the request that can be published in the Federal Register

REASONS WHY GRAN TING THIS REQUEST FOR EXEMPTION WOULD BE IN THE PUBLIC INTEREST AND WOULD NOT
ADVERSELY AFFECT PUBLIC SAFETY :

Batteries power the UAS described in this petition ; and they are smaller, lighter and more maneuverable than larger aircraft running on combustib le fuel . The UAS operates at lower altitudes with no people on board and will thereby reduce current risk levels associated with traditional aircraft, enhance safety and greatly diminish the likelihood of death or serious bodily injury. The environmental i mpact (including air and noise pollution) caused by the UAS is also less than traditional aircraft, based on its smaller size, more limited flight times and alternative power source. Also

, with a small payload and typical flight time of only 20 minutes, as well as the restricted secure environments in which the UAS would be operated, there is little or no risk to national security. The photography and video available from UAS could previously only be obtained u sing fully manned aircraft,
which was cost

- proh ibitive for many applications. The lower cost and improved photographic quality from the
UAS will be a benefit to many small businesses that would otherwise be unable to afford high quality aerial imagery

. Additionally, we plan to make our UAS available to first responders in our community who might require assistance, including fire fighters, police, sheriff, et al., while remaining subject to all limitations cited in this application. Flight safety will be maintained at a level that is equivalent to trad itional flight operations, by2

2

Exemption Request Section 333 Aerial PIC llc Docket ID FAA

- 2015

- 1763

- 0001 Jeff Webbe, Owner & Operator 17941 W. Jojoba Rd., Goodyear, AZ 85338 jjwebbe@gmail.com an FAA licensed pilot in a manner consistent with safe o peration, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

ADDITIONAL INFORMATION, VIEWS OR ARGUMENTS TO SUPPORT THIS REQUEST:

Congress’s national policy favors early integration of UAS into the national airspace in controlled, safe working environments such as those proposed in this petition. Those goals are furthered when businesses such as A erial PIC llc are granted exemption, thereby helping to facilitate and promote the safe integr ation of UAS into the NAS, while provid ing education and awareness of UAS operations and capabilities. By providing lawfully operated UAS photography and videogra phy in our geographical region, Aerial PIC llc offers a safer alternative to the public at large, in comparison with those who are currently operating UAS illegally in national airspace.

SUMMARY:

The petitioner

, Jeff Webbe, owner and operator of Aerial P IC llc, request s relief from Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, to operate the DJI Inspire 1 Unmanned Aircraft System (“Inspire 1”) and the DJI Phantom 3 Unmanned Aircraft System (“Phan tom 3”). The extent of the relief specifically applies to the following Federal Aviation Regulations: 14 C.F.R. Part 21; 14 C.F.R. Part 36 Noise Standards; 14 C.F.R. 45.23(b) Markings and Registration Number; 14 C.F.R. 61.113(a) & (b) Private Pilot Privileges and Limitations; 14 C.F.R. 61.133(a) Commercial Pilot Privileges and Limitations; 14 C.F.R. 91.7(a) & (b) Civil Aircraft Worthiness; 14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual Marking and Placard Requirements; 14 C.F.R. 91.119 Minimum Safe Altitudes; 14 C.F.R. 91.121 Altimeter Settings; 14 C.F.R. 91.151(a) & (b) Fuel Requirements in VFR conditions; 14 C.F.R. 91.203(a) & (b) Airworthiness Certificate; C.F.R. 91.207 Emergency locator transmitters ; 14 C.F.R. 91.405(a) Maintenance Inspections; 14 C.F.R. 91.407(a)(1) Mainte nance Inspections; 14 C.F.R. 91.409(a)(2) Maintenance Inspections; and 14 C.F.R. 91.417(a) Maintenance Inspections. The requested exemptions would allow the petitioner to use the Inspire 1 and Phantom 3 Unmanned Aerial Systems for commercial purposes such as obtaining aerial images, photos and video footage for use in marketing, real estate, agriculture, insurance, surveying, aerial photography and videography, construction, events, police and governmental support, a nd search and rescue operations

.

Sin ce rely,

Jeff Webbe Owner & Operator, Aerial PIC llc