October 21 , 2015

U. S
. Department ofTransportation Docket Management System 1200 New Jersey Ave. , SE Washington , DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act. Dear Sir or Madam : Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Act"), William E
. Crum , the operator and applicant, planned operator of Unmanned Aircraft Systems (UASs) equipped to conduct aerial photography and digital point cloud surveys for various industries hereby applies for an exemption from Federal Aviation Regulations (FARs) to allow commercial operation of our UASs, 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
. As described more fully in Appendix 

### A, the requested exemption would permit the operation of UAS(s) by the operator for commercial use that would provide the following benefits : 1
. Operations would be performed in an area of operation limited in size suitable to the specific use , in advance of flight. 2
. The flight would be planned in advance to minimize hazards to persons and property in the air and on the ground. 3
. The operator would reasonably limit or control access to provide safety to those not involved in the operation. 4
. Operation of a UAS would provide sign ificant safety, environmental and other enhancements not possible by larger sized aircraft
. 5
. An FAA licensed airman with a Commercial Pilot Certificate would operate the UAS or directly supervise the operation
. 6. Provide a beneficial and currently unavailable service to government organizations and the general public that would serve the public interest. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrators) respons ibilities to "
...establish requirements for the safe operation of such aircraft systems in the national airspace system. "Section 333(c) of the Reform Act. It is possible to operate an UAS so to not create a hazard to users ofthe National Airspace System (NAS), the publ ic or pose a threat to national security if done so safely and responsibly
. The applicant has demonstrated their willingness to act safely and responsibly by not engaging in commercial UAS operations
. The applicant has worked within FAA guidelines to obtain a legal authorization to conduct commercial operations
. Additionally, the fact that the applicant currently holds a FAA Commercial Pilot Certificate demonstrates that the applicant has a high regard to safe operations, as well as a necessary high-level understanding of the NAS and FARs
. The experience of a FAA certificate serves to add significantly to the level of safety in any operation performed by the applicant or the app licant's employees
. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics of UAS and that operate with the limitations listed herein
. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure as the proposed operations represent a safety enhancement to the already safe aerial commercial photography and survey operations conducted with conventional aircraft
. The UAS planned to be operated is the OJI Phantom 3 Professional rotorcraft
. The unmanned aircraft (UA) is equipped with four rotors that ar e driven by electric motors , powered by batteries , and weigh less than 3 pounds, including payload. The UA would have a maximum airspeed of 30 knots
. The principal construction material ofthese UA is plastic
. Operations will be performed by a qualified UAS Pilot in Command (PIC) , as outlined below, to insure that the UAS will "not create a hazard to users of the national airspace system or the public
." Given the small size ofthe UAS involved and the preplanned environment within which they will operate, the appl icant believes that these operations fall squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption , allow commercial operations of UAS to commence immediately
. Also , operation in a researched (to include applicable NOTAMs) , pre-defined area will prevent the possibility of a national security issue. The operation of UASs by knowledgeable professionals with experience in the NAS will serve to enhance safety, add to the public benefit and reduce environmental impacts related to current methods of aerial photography and survey. These limitations and conditions to which the operator, or its employees, acting as an UAS PIC, agrees to be bound when conducting commercial operations under an FAA issued exemption : 1
. Safety will be the first and foremost consideration in any UAS operation
.2
. The UAS pilot will be an FAA licensed airman with at least a Commercial Pilot Certificate or the UAS pilot wi ll be directly supervised by an FAA licensed airman with at least a Commercial Pilot Certificate
. 3. The UAS Pilot, and observer will hold at least a Second C lass Medical Certificate
. 4. The UAS FAA licensed airman will be considered PIC , whether flying or supervising , and will be responsible for safe operation ofthe flight. 5. Flights will be conducted within line of sight ofthe PIC and an observer
. 6. Flights will be conducted in Class G airspace whenever possible. If an operation in another airspace is required , the relevant controlling agency will be notified at least 24 hours prior to the operation and , if required , any necessary permission obtained. 7. Flights will be conducted under visibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR)
. 8
. The UAS will at all times give way to any aircraft, object, or persons. 9
. Minimum crew for each operation will consist of the UAS PIC and an observer
. The observer and PIC will at all times maintain visual line of site to the UA, and be able to communicate by voice . 10
. Prior to a UAS flight, an area of operation will be established
. This area of operation will include a defined lateral and vertical area, where the UAS will operate
. Safety procedures will be established for persons, property and applicable airspace within the area of operation
. 11
. Flight planning will include flight completion with at least 20% battery power remaining as measured by the UAS or appropriate timing
. 12. The UAS will utilize GPS navigation , failsafe , return-to-home (RTH) and/or flight abort safety features. 13. A briefing will be conducted in regard to the planned UAS operations prior to operation at each new location
. All personnel who will be performing duties within the boundaries ofthe area of operation will be present for this briefing
. 14
. All required permissions and permits will be obtained from appropriate state, county or city jurisdictions, including local law enforcement, fire , or other appropriate governmental agencies
. 15
. Written , to include electron ic, and/or oral permission from the relevant property owners will be obtained prior to an operation
.16
. The UAS pilot will be trained in advance for the safe operation of the UAS to be operated
. This will include operation ofthe UAS both in normal and emergency modes of operation as applicable , and will include familiarization with the operation manual (or similar) if published by the UAS manufacturer. Training will also include types of maneuvers to be performed and the safe operation in relation to persons, property and applicable airspace
. It is the applicant's belief that the size, speed , operating environment, limitations, and level of applicant's experience in the NAS outlined provides an "equivalent level of safety" or better when operating a UAS for the public interest as outlined in Section 333 in the FAA Modernization and Reform Act of 2012. It is requested that the FAA issue an exemption to permit safe, legal , commercial UAS operation by the applicant as soon as possible
. Sincerely, 

# wllkun 

# c**~** William E. Crum 5036 Middleway Pike Kearneysville, WV 25430 Billcrum5036@comcast.net 304-261-2466

Appendix A Exemption Requests and Equivalent Level of Safety Appendix 8 DJI Phantom 3 Professional User Manual