Submitted by: David L. Thomas 210 P eninsula Circle Newnan, GA 30263 770 253

- 1060 David@DavidL

Thomas.com
Scope: Enhance the academic community awareness and augment real estate

listing videos by using the Phantom Vision3 and the inspire 1 U nmanned Aircraft System to conduct aerial photography and videography of real property

. Re quest: An exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405(a),

91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) of Title 14, Code of Fe deral Re gulations (14 CFR) as was granted to Douglas T rudeau, Realtor® in Exemption No. 11138.

Pe tition: The following documents are included with the P etition:

Phantom_3_Professional_User_Manual_v1.0_en.doc, Inspire_1_User_Manual_v1.2_en.doc , Safety_Guidelines.doc Atlanta sectional map with anticipated operating area.
I request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance Inspections since they only apply to aircraft with an airw orthiness certificate. I will, however , perform a preflight inspection of my UAS before each flight as outlined in the operating documents.
UAS Pilot in Command (PIC) The Pilot in Command of my UAS will hold a Priv ate Pilot's license, a third class medical certificate, and will have many hours of practice and, when one is available, attend the Phantom Pilot Training Course offered by the manufacturer

. UAS Operating P arameters I request exemption from § 91.151. The Pilot in Comma nd will abide by the following personal protocols and controls:

P i l o t i n C o m m a n d w i l l o n l y o p e ra t e i n re a s o n a b l y s a fe e n v i r o n m e n t s that are strictly controlled, are away from power lines, elevated lights and airports. Pilot in Command will conduct extensive preflight

inspections and protocols, during which safety carries primary importance;

O p e ra t e t h e U A S b e l o w 3 0 0 fe e t a n d w i t h i n a ra d i u s d i s t a n c e o f 1000 feet from the controller while maintaining direct line of sig ht visual observ ation (VLOS);

L a n d t h e U A S p r i o r t o t h e m a n u fa c t u re r ' s re c o m m e n d e d m i n i m u m leve l of battery power;U s e t h e U A S ' G P S fl i g h t s a fe t y fe a t u re w h e re b y t h e a i rc ra f t h o v e r s and then slowly lands if communication with the remote control pilot is lost;

P i l o t i n C o m m a n d w i l l c o n d u c t a l l o p e ra t i o n s u n d e r m y o w n personal and flight safety protocols (including posting a warning sign reading: "Attention: Aerial Photography in Progress

- Re main Back 150 feet") contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance my safety protocols;

C o n t a c t r e s p e c t i v e a i r p o rt s a n d / o r F l i g h t S t a n d a r d D i s t r i c t O f f i c e s i f op erations will be within 5 miles to advise them of my estimated flight time, flight duration, elev ation of flight and other pertinent information;

I w i l l a l w a y s o b t a i n a l l n e c e s s a ry p e r m i s s i o n s p r i o r t o o p e ra t i o n ; and

H a v e p r o c e d u re s i n place to abort flights in the event of safety

breaches or potential danger

. §91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert that since there is currently no certificate applicable to my operati on, this regulation is inapplicable.
§91.119 prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. Pilot In Command will not operate the UAS above the alt itude of 300 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus "providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes." Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.
§91.121 Altimeter Settings is inapplicable since my UAS utilizes electronic GPS with a barometer sensor

. Public Interest Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, it's expense has been cost

- prohibitive. Granting this exemption to me would allo w me to provide this service at a much lower cost. My UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to manned aircraft. The operation of my UAS will minimize ecological damage and promote economic growth by providing information to companies looking to relocate or build in the Atlanta city and surrounding area.