08/09/15 Docket Operations, M-30 Peter P. Miller 4981 Mallet Hill Dr Cincinnati, Oh 45244

U.S. Department ofTransportation 1200 New Jersey Avenue, SE Room W12-140,West Building Ground Aoor Washington, DC 20590-0001 C/0 Brittany Newton



### Dear Brittany,

In response to your letter requesting more information on the Public Interest for my Exemption request under docket (No.FAA-2015-2045)

The Reason The Request would be in the Public Interest: The public interest in granting this exemption request is served by, among others, the following: The use ofUAS improves public safety and reduces risk by alleviating the public's exposure to danger and emissions associated with conventional aerial methods (full size aircraft) that are very heavy, fast and carry passengers, flammable fuel and cargo. A myriad ofecological and environmental benefits and improved economic efficiency and scientific information and data acquisition are potential public benefits accomplished through the use ofUAS for precision inspections ofinfrastructure and industrial plant and equipment such as energy pipelines, power lines, smokestacks, towers, and other manmade structures, which can be observed and later analyzed safely, accurately and unobtrusively. Commerce can be improved through data and image acquisition for real estate, construction, precision agriculture, surveying and other applications ofUAS technology. The visual arts such as film, photography and television are improved through exciting and beautiful images captured via the versatile aerial platform UAS provides, which benefits the collective cultural and aesthetic demands and desires ofan appreciative public. UAS may be an exceptional tool forjournalists and all manner ofnews gathering and reporting media, to

serve the public good in enhancing accurate dissemination ofnewsworthy and relevant information to interested citizens. Approval ofthis exemption will provide immediate employment opportunities for individuals and businesses whose livelihood may be directly or indirectly improved through career opportunities andjob creation in a growing technology sector ofthe economy. Congress has established a national policy that favors prompt integration ofUAS into the NAS, provided thatjudicious and reasoned agencies and officials guide the process prudently and with due emphasis on public safety and efficiency. The granting ofthis Petition for exemption will serve this public policy mandate and result in the attendant benefits perceived by this policy.

Peter P MillerU.S. Department ofTransportation, Peter P. Miller 4981 Mallet Hill Dr Cincinnati, Oh 45244

Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

05/20/2015

Petition for 333 Exemption
I, Peter P. Miller, Airline Transport Pilot (airman certificate #3028069), of4981 Mallet Hill Dr. Cincinnati Oh. 45244, am petitioning the Federal Aviation Administration (FAA) for an exemption from part 21, subpart H; and Sections 45.23(b), 91.9(b)(2), 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) ofTitle 14, Code ofFederal Regulations (14 CFR). This proposed exemption would allow me to operate a DJI Phantom Vision 3 Quad Copter Unmanned Aerial System (UAS) for the purpose of aerial mapping, videographer and real estate photography. The use ofa UAS for these activities will have a substantial social benefit Itwill bring an over-head perspective to future customers thatwere previously only possible through the prohibitively expensive use ofrotorcraft and fixed wing aircraft with expensive

camera equipment. Iwould bring this service at an affordable price and due to the simple nature ofthe UAS, with substantial savings. Due to the ever-improving nature ofthis technology a new UAS can become obsolete within a few months ofrelease. I am also seeking an exemption in addition theto

one listed above, to include other unmanned aerial systems (UAS) that meetthe operational limitations outlined in the notice ofproposed rulemaking (NPRM) pertainingto the operation ofsmall unmanned aircraft systems in proposed part 107 to Title 14 Code ofFederal Regulations (14 CFR). Safety Iwill utilize myknowledge as a professional pilotto maintain the highestlevel of safety during the proposed use ofthe UAS. Flight would consist ofthree parts: preflight, flight and post flight. The preflightwill consist ofextensive inspections ofthe area, the UAS and the airspace in which itwill be operating. Adetailed inspection ofthe UAS will be conducted and all major systems will be examined, including power plant, airframe and controls. Any discrepancy will be noted and ifthe discrepancy affects the safety ofthe flight, the flight will not commence. Operations will only commence in reasonably safe environments thatwill be strictly controlled during the flight ofthe UAS. The area will be surveyed for power lines,elevated lights and otherpropertywith the potential to affectthe safety ofthe flight Therewill be no flights within the proximity ofactive airports withoutfirst contactingthe appropriate agencies or authorities to ensurethe highestlevel of safety and compliance with all regulations. Operations will also notcommence where there is a reasonable possibility ofinadvertentphysical contactwith the populace. During the flight portion ofthe operation, safetywill bethe primary concern. Given the size, weight, speed and limited operating area ofthe UAS; flight will be inherently safe. The UAS will notbe operated above individuals not associated with its operation and care will be given to avoid propertythatwas noted duringthe preflight inspection ofthe area. During the post-flight debrief, all individuals associated with the operation will evaluate the success ofthe operation and address any concerns broughtforward aboutthe safety ofthe flight Any pertinentissues will benoted and action will be taken to ensurethe safety offuture flights. Exemptions from regulations All proposed exemptions from regulations are listed below and are accompanied by reasoning as to whyitwould be unreasonable to comply with the regulation.

• 14 CFR § 21 Subpart H: Airworthiness Certificates and 91.203 (a) and (b): Certifications required

o Given the size, weight, speed, and limited operating area associated with the aircraftto be utilized, an exemption is requested and would meetthe requirements for an equivalent level ofsafety under 14 CFR part 11 and Section 333 ofP.L. 112-95 (Section 333)

• 14 CFR § 45.23: Display ofmarks; general

o An exemption is requested because the UAS has no cabin, cockpit or pilot station on which to display certain words orphrases. Furthermore, is would be unreasonable to markthe aircraftwith 2 inch lettering since the airframe has dimensions smallerthan the minimal lettering requirement Iwill place the word ,Experimental" on the airframe ofthe UAS as required by§ 45.29(f) so that anyone assisting as a spotterand Iwill seethe markings.

• 14 CFR § 91.9 (b) (2): Civil aircraft flight manual, marking and placard requirements

o An exemption is requested from the cited regulations because the UAS manufacturer does not supply a flight manual that contains information found in manuals supplied by manufacturers oftraditional aircraftAlso, due to the size, weight, speed and operating area ofthe aircraft to be utilized itwould be unrealistic to expect itto.

• 14 CFR § 91.119: Minimum safe altitudes

o An exemption is requested from the cited regulations due to the purposethatthe UAS being used was created for. This UAS is designed for use in an environmentthatis contraryto this regulation. Also, theUAS would notbe operated at an altitude ofmorethan 500 feet above the surface, as to notinterferewith anypotential airtraffic. • 14 CFR § 91.121: Altimeter settingso An exemption is requested because no pitot static system is installed in the aircraft and due to the altitudes is operates at, adherenceto this regulation would be unrealistic and unnecessary. Also, GPS position information is transmitted to the aircraftcontroller, providing much more accurate information than whatwould be shown by a traditional altimeter.

• 14 CFR § 91.151: Fuel requirements for flight in VFR conditions

o Due to the nature ofthe aircraft being used, adherence to the regulation would be unrealistic. The UAS has an average flight time of approximately 25 minutes and a "return to home" function in the event ofan impendingpowerfailure. Therefore, an exemption from the cited regulation is requested.

• 14 CFR § 91.405(a): Maintenance required, 91.407(a)(1): Operation after maintenance, preventative maintenance, rebuilding oralteration, 91.409 (a)(2): Inspections, 91.417(a) and (b): Maintenance records

o Exemptions arerequested from the cited maintenance regulations because they only apply to traditional aircraftwith an airworthiness certificate. Qualifications and closing By granting me a section 333 exemption Iwill be able to bring a service to my communitythatbefore, was associated with high cost and high environmental impact As a professional pilot, the skills and knowledge that Ihave gained through training and experience will add an additional level ofsafety to the operation ofthe UAS. Coupled with an in-depth knowledge ofairspace, Federal Aviation Regulations (FARs), safety offlight and science offlight information I believe there should be no question as to the soundness ofmy petition for exemption. *Note All information regardingthe DJI Phantom 3 quad copter can be found on the manufacturers webpage below. Model specifications will be submitted with this document for ease ofreference. http://www.dji.com/product/Phantom

.

Sincerely,

Peter P. Miller



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