US Department ofTransportation Exemption Request Pursuantto Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation November2, 2015 Richard A. Meuse 26 Washington Ave. Stoneham MA, 02180 N1 hid1951 @verizon.net

U.S Department of Transportation Docket Management System 1200 NewJerseyAve., SE Washington DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14CFR 91.103; 14 CFR 91
.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14CFR 91.409 (a)(1) and (2) ; 14 CFR 91.417(a) and (b)

Dear Sir or Madam: Pursuantto Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") And 14 CFR Part 11 of Unmanned Aircraft Systems (UAS), Richard A. Meuse Hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of Designated UAS, provided such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.

Thankyou in advance for your consideration.Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 1. Real Estate 2. Aerial Photography

### I Videography 3. Search and Rescue As described fully below, the requested exemption would permitthe operation of designated UAS asset forth in this document under controlled conditions in the NASthat would be a) limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase public awareness of UAS operations and enhance safetyto aid in fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibilities to''
....establish requirements for the safe operation of such aircraft systems in the national airspace system."
The name and address ofthe applicant is Richard A. Meuse 26 Washington Ave. Stoneham MA, 02180 N1 hid1951 @verizon.net
From which theexemption is requested:14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) 

### &(b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14CFR91.151 (a) 14 CFR 91.203 (a) 14 CFR 91.405 (a) 14 CFR 91.407 (a) 14CFR 91.409 (a) 14 CFR 91.417 (a):
Grants of exemption in circumstances similar in all material respects, In Grants of Exemption Nos. 11062to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109to Clayco, Inc
. (see Docket No.FAA-2014-0507), 11112to VDOS Global, LLC (see Docket No
. FAA-2014-0382), 11213to Aeryon Labs, Inc
. (see Docket No. FAA-2014-0642), and 12645to Allied Drones (see Docket No
. FAA2014-0804) Exemption Nos. 11062, 11109, 11112, 11213, and 12645; Nos
. 11062, 11109, 11112, 11213,and 12645. Richard A. Meuse Will operate one or more of the Following model UAS DJI Phantom 3 Pro, Vision 2+, Inspire 1 Safety requirements, the approval ofthis application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly,the applicant graciously requests thatthe FAA grant the requested exemption
. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft
.These limitations and conditions to which the applicant agrees to adhereto when conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:
I.The UAS will weigh significantly lessthan 55 lbs. It weighs less than 4 pounds with battery and camera.
2. The UAS, depending on the model in operation,will have a maximum operating speed of no more than 50mph.

3. Flights will be operated within line of sight ofthe Pilot in Command (PIC) and/or Visual Observer (VO).
4. Maximum flight time for each operational flight will be depending on the UASmodel in operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first.
5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200feet above an elevated platform from which filming is planned. 6
. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO), and may include athird, but separate, Camera Operator (CO).
7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged a minimum of 20 hours on the designated UAS. 8. A safety briefing will be performed priorto each day'sflights consisting of all the day's activities. 9. All flight activities will be logged. 10. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only. 11
.The flights will occur in Class G airspace no closerthan a mile radius ofthe geographic center/Airport Reference Point (ARP) of atower controlled or uncontrolled airport
. 12. Flights will not be closerthan a 5-mile radius of the geographic center/Airport

. 13
.The operatorwill do a pre check of aircraft prior to each flight. And log each flight. 14. The operatorwill obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as U
.S. Department of Transportation required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved.
15
.The PIC and VO will have been trained in operation of UAS and receive up to date information for the particular UASto be operated.16. The PIC and VO will be able to communicate byvoice and/or radio at all times.
17
.The PIC will abide by all rules
. 18
. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capabilityto return to a predetermined location within a designated location and land autonomously.
19. The UAS will have the capability to abort aflight in case of emergencies with an automated 11Return Home and Land 11 function.
20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies such as low battery
.

14 C.F.R

. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U
.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAAto exempt aircraftfrom the requirementfor an airworthiness certificate, upon consideration of the size, weight,speed, operational capability, and proximityto airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates thatthe UAS operated without an airworthiness certificate in the restricted environmentand underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements
.These safety enhancements provide a greater degree ofsafetyto the public and property owners than conventional operations conducted with airworthiness certificates issued under14 C.F.R. Part

### 21,Subpart H. Lastly, application of these same criteria demonstratesthatthere is no credible threatto national security posed bythe UAS, dueto its size, speed of operation, location of operation, lack of explosive materials orflammable liquid fuels, and inabilityto carry a substantial external load. 14C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires:When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft,the operator mustalso displayon that aircraft neareach entrance to the cabin, cockpit, or pilot station, in letters not lessthan 2 inches nor morethan 6 inches high,the words "limited/' "restricted/' "light sport/' "experimental/' or "provisional/' as applicable.
The operator must also display on that aircraft neareach entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited/' "restricted/' "light sport/' "experimental/' or "provisional/' as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed, as the UAS will have no entranceto the cabin, cockpit or pilot station on which the word lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). US Department ofTransportation February

### 20,2015.
The equivalent level of safetywill be provided by having the UAS marked With a N number and or Experimental. Given the size of the UAS,two inch on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UASwill see the identification ofthe UAS, 14C.F

.R. § 61
.113 (a) and (b).

The proposed UAS operations may achieve an equivalent level of safety as achieved bycurrent Regulations becausethe applicant's UAS do not carry any pilots or passengers nor property.
14C

.F
.R
. §91.7{a): Civil Aircraft Airworthiness
.The regulation requires that no person mayoperate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraftfor maintenance and use of safety checklists priorto each flight, an equivalent level of safetywill be provided. 14C

.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) {2) provides: Noperson may operate a U.S. registered civil aircraft
... (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21

.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only becausethere is no pilot on board, but because there is no room or capacityto carry such an item on the aircraft. The equivalent level of safetywill be maintained by keeping the flight manual atthe ground control point where the pilot flying the UAS will have immediate accessto it. 14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flightto insure the safety offlight. As FAA approved rotorcraftflight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 14 C.F.R

. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls
. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions for flight training withoutfully functional dual controls for a numberof aircraft and forflight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.
14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicoptersto be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA
.As this exemption is for a UASthat is a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations
.As setforth herein, the UAS will never operate at higherthan 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre obtained consent.The equivalent level of safetywill be achieved given the size, weight, and speed of the UAS as well as the location where it is operated
. No flight will be taken without the permission ofthe property owner or local officials
. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum SSibs

. Proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119. 14 C.F

.R
. §91.121 Altimeter Settings. This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "
... to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent level of safetywill be achieved bythe operator, pursuantto the safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 14 C.F.R

. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The applicant believes that an exemption from 14CFR §91.151 (a) falls within the scope of prior exemptions. Operating the UAS in atightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does not engenderthe type of risks that Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. The applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power- whichever happens first. This restriction would be more than adequateto return the UAS to its planned landing zone from anywhere in its limited operating area.
14C

.F
.R
. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person mayoperate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate
... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs well underthe proposed 55 lb limit and isoperated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the UAS. An equivalent level of safety will be achieved by keeping these documents atthe ground control point where the pilot flying the UAS will have immediate accessto them, to the extentthey are applicable to the UAS.
14 C.F

.R
. §91.405 (a); 407 (a) (1);409 (a) (2);417(a) & (b): Maintenance Inspections. These regulations require that an aircraft operator or owner "shall havethat aircraft inspected as prescribed in subpart Eof this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter
..," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not applyto the applicant. Maintenance will be accomplished bythe operator pursuantto the flight manual and operating handbook. An equivalent level of safetywill be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feet AGL. The operatorwill ensure that the UAS is in working order priorto initiating flight, perform required maintenance, and keep a log of any maintenance performed
. Moreover,the operator is the person mostfamiliarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspectionswill be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, and a link on last page,the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed. Authority contained in 49 U
.S

.C. 106(f), 40113,and 44701. Additional Information
. Richard A. Meuse believes this exemption request and associated safety considerations adequately satisfy criteria provided in Section 333 of the Reform Act of 2012, providing sufficientjustification for the granting of commercial operations of the applicant's UAS

.



### . . The applicant Richard A. Meuse requests your respective approval of this Section 333 exemption petition request.

Thank you for your attention in this matter. Please notify Richard A. Meuse Of your actions,and or approvals
.Thank you, for your interest in this request.Sincerely,

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