Laurie L. McCord, Section 333 Exemption Request

Laurie L. McCord 2285 Rolling Hills Drive Covington, KY 41017

July 27, 2015

Federal Aviation Administration: I am submitting my Petition for Exemption for Unmanned Aircraft Systems operations

. I have been a private pilot since 2006

. I take the skills and education for the safe operation of UAS, very seriously. My request is for a waiver of the sections identified below in an effort to operate a UAS in public for commercial purposes . I recognize the importance of extreme privacy as I have been in sit uations where I have had to adhere to an environment, and culture that is based on such privacy. I, Laurie L. Mccord,
w ould like to formally submit an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)2, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a) 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a) (1), 91.409 (a) (2), and 91.417 (a) and (b) of title 14 Code of Federal Regulations (14 CFR). This pr oposal exemption would allow operation of unmanned aircra ft systems (UAS) for the purpose of Aerial Videography, Aerial Photography and Aerial Survey to au gment real estate listings in the Greater Cincinnati and Northern Kentucky area. Regarding the Unmanned Aircraft PIC : I will operate a UAS, more specifically the DJI Phantom III , which is an unmanned aircraft (UA or PHANTOM), comprised of an attached high definition camera and a transportable ground station. I hold
a Commercial Pilot Certificate with more than two thousand hours of flight time. Having flown t housands of hours in a multitude of aircraft, I am well aware of the importance of pre

- flight planning and the significance of being safety oriented

. S afety is my number one priority in aviation. As a Commercial Pilot I have always been required to hold at least a second class FAA Medical Certificate to operate under those privileges. Flying a UAS is no exception when it comes to fitness of flight and I intend to operate the UAS as I would any aircraft, always being in peak physical and mental condition. This will allow for safe operations on the ground and in the air, just as it is done in manned aircraft. Regarding the Operation of the Unmanned Aircraft : With my clear understanding of FAA regulations, my experience in flying in all kinds of airspace and my safety first attitude, I believe that I should be granted an exemption. I am well aware of the importance of safe flight operations and planning flight paths that minimize any overflight of crowds or in the vicinity of other manned aircraft

. My request for a n exemption is specifically to reco rd digital video data, aerial photography data and any other aerial surveying of privately owned property. These images will assist the real estate agent and the owner in marketing the property to the public.

P reflight and post

-flight checklists and UAS examinations will help detect any abnormalities prior to flight and after flight. Any UAS unable to satisfy safety checklists will be removed from service until the issue can be resolved. The UAS will not be operated above 200 feet AGL and will not be flown in wind conditions greater than eight knots (8 kts). The UAS will operate in temperatures between 0 degreesLaurie L. McCord, Section 333 Exemption Request

Celsius and 40 degrees Celsius (32 degrees Fahrenheit

– 104 degrees Fahrenheit) as that is the ran ge for the craft. Flights outside those temperature parameters will not be attempted. Furthermore, the UAS will maintain at least the Basic VFR Weather Minimums prescribed in 14 CFR 91.155 and operations will only commence during visual meteorological co nditions. If a property being enhanced by videography, photography or survey is within close proximity to a towered airport, I will call the control tower and request permission to operate the UAS. Upon contact with the control tower I will alert them t o the location of the property to be filmed, photographed or surveyed and provide the proximity of that property to the airport. I will also give a minimum of a 24 hour notice before filming or photographing the property. If permission is not granted, op erations with not be conducted. Before operating within clo se proximity to another structure, building or person , the own er and/or those who live at the aforementioned will be given notice that aerial photography, videography or surveying will commence. Any complaint by a neighbor or member of the public worried about their privacy being invaded, will be ensured that only the property being videoed will be used for marketing purposes. If this is not sufficient, the DJI Phantom III will immediately be bro ught back to the ground and the videography, photography or surveying will cease until the complaint is resolved. The UAS will only be operated with direct line of sight visual contact between the pilot in command and the unmanned aircraft. This will further ensure safe operational control as the pilot in command will always have visual line of sight on the UAS in order to s can the airspace it is operating in so as t o see and avoid other aircraft, airborne objects or objects on the ground. Moreover, I wil l operate in congested areas with another person (spotter) in order to help spot the UAS from other angles to verify operations will be conducted safely. The spotter who will assist will also be another trained and certificated pilot in order to more safely conduct operations. Additionally, in order to further enhance safety, f lights will end when battery reserve reaches 25 percent. The UAS has a 15.2 volt battery, allowing flight operations for up to 23 minutes. I have also purchased a second battery allowing for an additional 23 minutes of flight time. Operations with the UAS will not occur under IFR conditions. It is my understanding that g ranting this request would not adversely affect safety since operations would be in accordance with current U AS rules. Prior to commencing operations, I, the operator will obtain a COA from the FAA

. Suggested P ublic Federal Register Summary: “The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) u nder the new FAA ‘Summary Grant’ approach, announced April 9th, 2015 that will hasten the Section 333 exemption approvals for many commercial UAS operators prior to finalizing the small UAS proposed rules published this past February. ” It is my understanding that the FAA will still revie w each Section 333 petition individually. However, I am hoping that the agency will ac cept my particular petition, include it in the next summary grant and issue an exemption to myself on the presumption that the FAA has already granted a previous exemptio n similar to this request.Laurie L. McCord, Section 333 Exemption Request

Currently, the new interim policy includes the granting of a Certificate of Waiver or Authorization (COA) for flights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pou nds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports such as 5 nautical miles (NM) from an airport havi ng an operational control tower or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operational tower; or 2 NM from a heliport wit h a published instrument flight procedure. It is also understood that the “blanket” 200

- foot COA allows flights anywhere in the country except restr icted airspace and other areas, such as major cities, where the FAA prohibits UAS operations. UAS Descript ion: I am asking for an exemption for a UAS up to 55 pounds because I will be using a craft that will be flown operationall y, weighing less than ten pounds. M ore specifically, I will be operating a DJI Phant om III, which will be qualified as a UAS. The UAS can fly for up to 23 minutes in temperatures between 0 degrees Celsius and 40 degrees Celsius. The UAS has a Sony EXMOR camera mounted on it with a gimbal. The remote control allows for a smartphone or tablet to be used in order to operate the drone w ith a live feed from the Sony camera mounted on it. This permits operation with a high level of safety.
In th e event a loss of communication occurs with the UAS, it will automatically rise up vertically to a safe height before beginning an automatic ret urn to home function. The control signal may be reconnected in flight and the pilot can take over safe operations again if communication is reestablished. However, in the case of a GPS failure the craft will be able to be manually flown to a safe landing by the pilot. The craft operates electronically, carries no flammable fuel, has an integrated GPS pilot system, location information along with height in AGL, speed, battery life, has programmed no

-fl y zones for controlled airports and provides direction o f travel distance from the pilot. Section 333 Compliance and Appropriateness:
Based on the size of the UAS, experience of the pilot, and operational goals, this request appears to be well suited for approval using the current criteria outlined in Section 333 of the FAA Modernization and Reform Act of 2012 (including new interim policies)

. It is my hope that you find that the enhanced safety achieved using an unmanned aircraft with the specifications described by the petitioner which carries no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Sincerely, 

# Lau rie L. McCord

Laurie L. McCord