To: U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room Wl2-140 1200 New Jersey Avenue, SE Washington, DC 20590

From: StephenWarriner 39 Pine St. PO Box 1819 Edgartown, MA 02539 508-259-3062 stephen@mvweb.com

Amendmentto: Public Docket (No. FAA-2015-0978) .1_

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.P.R. Part 11, Stephen Warriner, an individual, seeks exemption from requirements of 14 C.F.R. § 21, Subpart H; 14 C.F.R. § 43.11; 14 C.F.R. § 91.103; 14 C.F.R. § 91.105; 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.P.R.§ 91.405(a) and (d); 14 C.P.R.§ 91.407(a)(l); 14 C.F.R. § 91.409(a)(2); 14 C.P.R. §417(a) and (b) to operate an unmanned aerial vehicle (UAV) in support ofcommercial aerial photography and videography ofindividual commercial, public, and residential properties and structures with owners/operators permission and appropriate authorization.

The request for this exemption is in the Public Interest as there are many consumer applications for the services that can be provided by UAVthat are currently conductedby manned aircraft. Using a UAV for many ofthese applications creates an environmentally friendly, lower cost solution to boththe operator and consumer. These aircraft can be operated safely, and without significant financial impactto the operator or any person or property on the ground in the event ofthe loss ofan aircraft. Utilizing these UAV will create

a safe and more productive work environment, reduce environmental pollution andhave a positive impact onthe local economy, which is in the Public Interest.

Stephen Warrinerrespectfully request thatthe FAA grantthe following requested exemptions: 14 C.P.R.§ 21, Subpart H; 14 C.P.R.§ 43.11; 14 C.P.R.§ 91.103;14 C.P.R.§ 91.105; 14 C.P.R.§ 91.109; 14 C.P.R.§ 91.119; 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.151(a); 14 C.P.R.§ 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); 14 C.F.R. §417(a) and (b).

14 C.P.R. 21, SubpartH: Airworthiness Certificate Stephen Warrinerrequests an exemption from 14 C.P.R. 21, Subpart

## i-L This Subpart establishes the procedures for the issuance ofan airworthiness certificate. Stephen Warriner requests an exemption from Part 21, SubpartH because the UAV is under 50 pounds ' ' ' i.(includingpayload) and meets an equivalent level ofsafety pursuantto Section 333 ofthe Reform Act due to its small size, light weight, and restricted operating environment. 14 C.F.R43.11: Records for Inspections Stephen Warrinerrequests an exemption from 14 C.P.R. 43.11. This partprovides that maintenance record entries be maintained, thatthe inspector list discrepancies, and to affix placards to the aircraft. Due to its small size the UAV proposed for use, does nothave room for placards to be placed in or on it and no inspections for UAV have been certified by FAA atthe presenttime. However, as a condition to the grant ofthe exemption, StephenWarriner will perform the inspections and time replaceable items recommended bythe manufacturer and keep records and log books ofall maintenance and repairs. 14 C.F.R 91.103: PreflightAction Stephen Warriner requests an exemption from 14 C.F.R. 91.103. This regulation requires each pilotto take certain actions before flight to insure the safety offlight. As FAA approved flight manuals will notbe provided for the UAV, an exemption is needed. Stephen Warriner will follow the manufactures preflight inspection. 14 C.F.R 91.105: Flight Crewmembers at Stations Stephen Warrinerrequests an exemption from 14 C.F.R. 91.105. Stephen Warrinerrequests

an exemption from 14 C.P.R. 91.105 since this part is not applicable due to the UAV carrying

no flight crewmembers. An equivalent level ofsafety will be maintainedby ensuringthe pilot does not change inflight.

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER Department ofTransportation Federal AviationAdministration Petitioner: Stephen Warriner Petition ofexemption from sections of; 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 SubpartE (91.405, 91.407, 91.409, 91.417) Description ofreliefsought; Stephen Warriner seeks an exemption for commercial operation ofan unmanned aerial vehicle that is under 50 pounds includingpayload. The unmanned aircraft vehicle has an onboard camera system capable ofacquiring high resolution data. Proposed operations will offer real estate aerial photography, videography and aerial surveying services for other commercial industries.