United States Department of Transportation Federal Aviation Administration 800 Independence Ave ., SW Washington, DC 20591

Petition For Exemption Parts of certain Title 14 CFRs in regards to Section 333 of the FAA Modernization and

Reform Act of 2012 Concerning Unmanned Aerial Systems (UAS)To whom it may concern: This letter is a request for exemption from a number of Title 14 CFRs that relate to the commercial operation of “unmanned aerial systems” (UAS). The following w ill be included in this request : Name of and information on the Petitioner; Executive Summary of the Petitioner summarizing the rules the Petitioner seeks exemption from and the reasons the exemptions would serve the public good; Specific Title 14 CFRs to which an exemption is sought; the extent & reasons for the requested exemptions; reasons why safety would not be compromised. **Personal Information:** Name: Greg R. Manuel (hereafter referred to as “Petitioner”) Company: The Sandner Group Claim Management Address: 1491 S. Bell School Road, Rockford IL 61108 815

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The Petitioner was born on January 15, 1962 and currently resides in Rockford IL. He is the Manager of the Loss Control Department for the Sandner Group Claim Management. The Sandner Group Claim Management is a third party claims administrator for public school intergovernmental cooperative s. The petitioner seeks authorization to perform commercial UAS operations for the purpose of conducting hazard and loss control inspections on public schools and other school district owned property. The Petitioner is an F.A.A. licensed Private Pilot, Airplane Single Engine Land with an Instrument rating

. The P etitioner intends to use a DJI Phan tom 2 Vision model P330D. This UAS has not been operated commercially and will not be operated commercially until an exemption to t h e current rules in Section 333 is granted. The Title 14 CFR exemptions that this request includes are: 61.113(a) & (b); 91 .7(a); 91.119(a); 91.121; 91.151(a); 91.407(a)(1) & (2); 91.417(a) & (b) . Reasons for each request are cited below. **Public Good** Aerial photography for geographical awareness and property inspection has been in use for many years with manned fixed wing a ircraft and helicopters. For public school districts however the cost is prohibitive and the altitudes used do not allow for up closedetail inspection photography. Having low cost UAS available for property inspections will enable public school districts to more effectively manage property maintenance needs and budget more effectively for roof repair or replacement. Granting this exemption to the petitioner would allow him to provide this service at a much lower cost, with better results obtained. Furt her, the small UAS being utilized will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. **Description of UAV to be deployed under requested exemptions** Petitioner currently owns a DJI Phantom 2 model P330D. The petitioner intends to use the Phantom 2 as the primary UAS in the commercial applications described herein. The Phantom 2 is a quad copter that can take off and land vertically. It weighs approximately 3 lbs. and has a maximum airspeed of approximately 25 knots. This UAS uses lithium polymer batteries which have approximately 20

– 25 minutes of total charge time. This gives this UAS approximately 15 minutes of flight time with sufficient remaining battery charge to land safel y. **Preflight** The petitioner will always follow procedures outlined in the UAS operator’s manual as to proper preflight inspection of all hardware, software, environment and any other factors needed to ensure a safe flight. **FCC Information** The UAS being deployed here is a DJI Phantom 2 model P330D. The remote control operates on a frequency of 5.728 GHz

– 5.85GHz. Published FCC range is 800 m (2624 ft.) with a sensitivity of

- 93dbm. **PIC Qualifications** As stated above the P etitioner holds an FAA Private Pilot certificate with Instrument rating . The P etitioner has been an active and current pilot for more than 35 years and possesses expert knowledge of the National Airspace System. The petitioner also has many years of experience operatin g radio controlled model aircraft as a hobby and has operated the Phantom UAS as a hobbyist

. The P etitioner will be the Chief Pilot for all company UAS operations and expects to be the PIC for all company operations performed. **Description of Intende d Commercial Operations**  Petitioner intends to utilize the UAS to perform aerial property inspections of public school districts. This work will be done with full permission of the subject schooldistrict. Flight operations will be restricted to flights directly over the property that has granted permission. **UAS Operating Parameters** The UAS being deployed in these exemption request can fly at a speed of approximately 25 knots. However, given the intended use described here, this speed will never be n ecessary. Much slower speeds are preferred to collect the photographic material needed. Flight operations will not be conducted when students are present outside the building being photographed. Petitioner agrees to never fly the UAS outside of VLOS and also agrees to only fly UAS during daylight hours in visual meteorological conditions, at altitudes below 200 feet AGL and clear of clouds. The UAS will not be operated within 5 nautical miles of an airport as denoted on a current FAA published aeronautical chart. The UAS being deployed with these exemption requests has the capability of using GPS signals to return to its initial point of takeoff if connection with the radio control link is lost. The Petitioner agrees to yield right of way to a ll manned aviation activities at all times. **Exemption Requests** The following is a list of Title 14 CFR’s which the P etitioner seeks exemption. Please note that the Petitioner has used Exemption No. 11583 issued to Thomas Raniere, Flite Video LLC (Regula tory Docket No. FAA

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- 0453) as a reference. **Rule 61.113 –**  **Private Pilot Previleges and Limitations** The Petitioner holds a FAA Private Pilot certificate that does not allow operation for compensation or hire. Regarding these limitations it seems that Exemption No. 11062 issued to Astraecus has allowed this exemption previously and is also noted in the Trudeau exemption no. 11138.
**Rule 91.7(a) Civil Aircraft Airworthiness** There is no current FAA regulatory standard for determining airworthiness of UAS and there is no certificate currently available for UAS airworthiness. Petitioner seeks anexemption from this rule by ensuring that the UAS is in an airworthy condition base d on compliance with the operating documents prior to every flight. Flight manual and other important documents will be kept in a location to allow them to be readily accessed by the PIC at all times. **Rule 91.119 (c)**  **Minimum Safe Altitudes** 91.119 prescri bes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. Petitioner seeks an exemption from this rule as Petitioner will only operate the UAS in a range from ground level up to but not exceeding 200’ (AGL) and will only operate in areas where flight can be safely conducted with no undue risk to the public. The P etitioner asserts that given the size, weight, maneuverability and speed of the UAS, an equivalent or higher level of safety will be achieved than is possible with manned helicopters. **Rule 91.121 Altimeter Settings** In light of the very short range, local and short duration of unmanned flights intended by UAS operation, the Petitioner does not believe this rule can b e applied. All flights will be conducted below 200’ (AGL). **Rule 91.151(a) Fuel Requirements for Flight In VFR Conditions** Petitioner seeks relief from this rule due to the UAS being deployed is battery operated and the requirements under this rule are not applicable. The UAS in question has First Person Vision (FPV) capabilities which transmits certain telemetry to a monitor where the PIC can monitor certain aspects of the flight including battery level. A typical battery for a Phantom 2 Vision Model P3 30D will last 20

– 25 minutes before total exhaustion. Certain battery level warnings are set where the PIC will know when the battery state is at 30% and 15% remaining charge levels. This will normally allow a flight of 12

– 15 minutes with sufficient remaining battery charge to allow a safe return and landing. Flights will always begin with a fully charged battery. **Rule 91.405(a) Maintenance Required, 91.407(a) Operation After Maintenance, Preventative Maintenance, Rebuilding or Alteration;**  **91.409(a) (2) Inspections: 91.417(a)(b) Maintenance Records**  Petitioner seeks relief from these rules due to it being an alternate inspection requirement of 91.409(a)(2) . The Petitioner will inspect and ensure UAS is in a condition for safe flight and adhere to all operating documents.**Supplemental Information** The Petitioner has provided the following information to support these requests for rule exemptions : Phantom 2 Vision Operation Manual, March 21, 2014 Revision **Closing** The Petitioner believes that exemption from the above listed Title 14 CFRs is warranted given Petitioner’s background as a Private Pilot with 35+ years of accident free experience as pilot in command , t he nature of and type of use that the UAS will be utilized for, and the size and we ight of the UAS being deployed itself

. The safety precautions the Petitioner has described in this Petition for Exemption will assure safe, hazard free operation that will benefit public school districts. Sincerely, Greg R. Manuel Sandner Group Claim M anagement Rockford, IL 815

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