#2451872v.1 Annapolis Drone Operati ons, LLC Andrew Steven Watmoug h, Managing Member 947 Old Annapolis Neck Road Annapolis, Maryland 214 03 443-822-6130 annapolisdroneops@gma il.com

July 8, 2015

U.S. Department of Trans portation Docket Operations, Room W12-140 West Building Ground Fl oor 1200 New Jersey Avenue , S.E. Washington, D.C. 20590

RE: Petition of Annap olis Drone Operations, LL C for Exemption pursuant to Section 333 of the FAA Reform Act.

Dear Sir or Madam,

Pursuant to Section 333 o f the FAA Modernization and Reform Act of 2012 (the “Reform Act”), and 14 CFR Part 11, Ann apolis Drone Operations, LLC and Andrew Steven Watmough (collectively, the “Applic ant”), private pilot and op erator of Small Unmanne d Aircraft Systems (“sUAS”) equipped to co nduct aerial photography and videography, hereby applies for an exemption from certain F ederal Aviation Regulatio ns (“FARs”) to allow commercial operation of its sUASs, so long as s uch operations are condu cted within and under con ditions outlined herein or as may be estab lished by the FAA as requ ired by Section 333.1

As described more fully b elow, the requested exem ption would permit the op eration of small, unmanned and relatively inexpensive sUASs undercontrolled airspace that i s (1) limited; (2) predetermined; and (3) co ntrolled as to access. App roval of this proposed exe mption would thereby enhance safety an d fulfill the Secretary of T ransportation’s (the “FAA Administrator’s”) responsibilities to “establ ish requirements for the s afe operations of such air craft systems in the national airspace system. ” Section 333(c) of the R eform Act.

SUMMARY

The Applicant is a media /technology company ow ned and run by Andrew S teven Watmough, and plans to operate a sU AS to provide commercia l services including aerialsurveying, event photography and videogr aphy, real estate photogra phy and videography and site inspections.

The Applicant seeks an e xemption to operate the D JI Phantom 3 Professiona l system (the “Phantom 3”) for compen sation or hire within the N ational Airspace (“NAS”) . The Phantom 3 is a vertical takeoff and land ing sUAS with a Ground Control Station utilizing e lectronic tablet or- 2 -

#2451872v.1 smart phone systems. Th e Phantom 3 has a maxim um gross weight of appro ximately 2.8 pounds, with a diagonal d imension of 23.2 inches, and a maximum speed of 16.4 feet per second. The Phantom 3 is equippe d with four main rotors an d driven by Lithium Poly mer battery powered electric motors.

Unmanned Aircraft Syste ms are oftentimes seen as superior to helicopters du e to the smaller devices, cheaper equipme nt and personnel costs, re duced noise, and much sm aller environmental impact which promotes p ublic safety. The Applica nt is petitioning for an ex emption to enable Annapolis Drone Operati ons, LLC to operate the Phantom 3 equipped with athree-axis camera gimbal and a 4K camera. This sUAS has a built in capability to limit the he ight it flies above the ground, and to limit the r adius of the distance it fli es from the operator. The Phantom 3 also has the fail safe function of th e autopilot system which means if the communicat ion between the main controller and the tr ansmitter is disconnected , the outputs of all comma nd sticks from the controller will go to the c enter position, and the sy stem will automatically tr igger Return to Home and will land safel y.
A copy of the Phantom 3 User Manual and Safety Guidelines (collectively, the “User Manual”) are attached to this Appli cation and should be refe rred to for all performanc e limitations and flight operations.

A pre-flight inspection w ill be performed by the Pi lot-in-Charge (the “PIC”) in accordance with the User Manual. Propel lers will be inspected pre -flight and any propeller w ith a nick or crack will be replaced with a m anufacturers authorized p ropeller. The sUAS will be maintained in accordance with the User Manual and only manufa cturer’s authorized replac ement parts will be used.

The sUAS will operate on ly in line of sight and wil l operate in accordance w ith the User Manual. All flights will occur ove r private or controlled acc ess property with the prop erty owner’s or their duly appointed repre sentative’s prior consent and knowledge.

The sUAS will be operate d by Mr. Watmough. Mr . Watmough possesses a p rivate pilot’s license and has over 200 hours experience as a pilo t in command. Mr. Watm ough has significant training and experience o perating the Phantom 3, i ncluding approximately 4 0 hours of supervised operations as the pilot in charge of the Phantom 3. Mr. Watmou gh’s experience will ensure that the sUAS is s afely operated at all times

. Statutory Authority Secti on 333, titled “Special Ru les for Certain UnmannedAircraft Systems,” provides a mechanism fo r seeking expedited FAA authorization of safe civi l UAS operations in National Airspace (“NAS ”). Section 333(a) states that the FAA “shall deter mine if certain unmanned aircraft system s may operate safely in th e national airspace system before completion of the (comprehensive) p lan and rule making requ ired by Section 332(b)(1) of this Act or the guidance required by sect ion 334 of the Act.” In S ection 332(b)(1), Congres s made it clear that Section provides a mecha nism for “expedited opera tion authorization” if seve ral factors are met. The Applicant meets all r equirements to permit FA A approval of commercia l UAS operations and such an exemption sh ould be granted.- 3 -

#2451872v.1 In accordance with 14 CF R § 11.81, the Applicant provides the following in formation in support of its petition for exempti on.

I. Contact Informatio n
Annapolis Drone Operati ons, LLC Andrew Steven Watmoug h, Managing Member 947 Old Annapolis Neck Road Annapolis, Maryland 214 03 443-822-6130 annapolisdroneops@gma il.com EIN – 47-4249237 Private Pilot FAA Numbe r 2718514

II. The Specific Section s of Title 14 of the Code of Federal Regulations From Which Annapolis Drone Opera tions, LLC Requests Ex emption are:

14 CFR Part 21 Subpart H 14 CFR Part 27, Airworth iness Standards: Normal Category Rotorcraft 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 14 CFR § 91.121 14 CFR § 91.151(a) 14 CFR § 91.203(a) & (b ) 14 CFR § 91.205(b) 14 CFR § 91.215 14 CFR § 91.405(a) 14 CFR § 407(a)(1) 14 CFR § 409(a)(2) 14 CFR § 417(a) & (b) 14 CFR § 91.401-91.417

III. The extent of relief y ou seek, the reason you seek the relief, and the r easons why the exemption will not a dversely affect safety.

14 CFR Part 21, Subpart H: Airworthiness Certific ates & 14 CFR § 91.203( a)(1)

Subpart H, entitled Airwo rthiness Certificates, esta blishes the procedural req uirements for the issuance of airworthiness certificates as required b y 14 CFR § 91.203(a)(1). Given the size and limited operating area ass ociated with Phantom 3, an exemption from Part 2 1, Subpart H meets the requirements of an eq uivalent level of safety un der Part 11 and Section 3 33 of the Reform Act.- 4 -

#2451872v.1 The Federal Aviation Act (49 USC § 44701(f)) and Section 333 of the Refor m Act both authorize the FAA to exe mpt aircrafts from the req uirement for an airworthi ness certificate, upon consideration of the size, weight, speed, operationa l capability, and proximit y to airports and populated areas of the particular UAS. In all cases an analysis of these crite ria demonstrates that a sUAS operated without an airworthiness certifica te, in the restricted enviro nment and under the conditions proposed will be at least as safe, or safe r, than a conventional airc raft (fixed-wing or rotorcraft) operating with an airworthiness certifica te without the restrictions and conditions proposed.

Here an equivalent level o f safety will be reached b ecause the sUAS to be op erated hereunder is less than 55 lbs. fully loa ded, carries neither a pilo t nor passenger, and carri es no explosive materials or flammable li quid fuels. Based on the sUAS’s light weight and carbon fiber and plastic construction, the s UAS will be at least as sa fe, if not safer than a conv entionally certificated aircraft perfo rming the same mission.

These safety enhancements, which already apply to civil aircraft operated in connection with existing inspection opera tions, provide a greater de gree of safety to the publi c and property owners than conventiona l operations conducted w ith airworthiness certifica tes issued under 14 CFR Part 21, Subpart H. Lastly, application of the se same criteria demonstr ates that there is no credible threat to nationalsecurity posed by the sU AS due to its size, speed of operation, location of operation, lack of expl osive materials or flamm able liquid fuels, and inab ility to carry a substantial external load.

14 CFR Part 27: Airworth iness Standard: Normal C ategory Rotorcraft.

14 CFR Part 27 sets forth the procedural requireme nts for airworthiness certi fication of normal category rotorcraft. To th e extent the Applicant’s s UAS would otherwise req uire certification under Part 27, as a rotorc raft, the Applicant reques ts an exemption from Par t 27’s airworthiness standard for the same rea sons identified in the exe mption request from 14 C FR Part 21, Subpart H.

14 CFR 45.23(b), 45.27(a ) and 91.9(c) – Marking a nd Identification Require ments
The Application seeks an exemption from the aircr aft marking and identifica tion requirements in 14 CFR 45.23(b), 45.27(a ), and 91.9(c). These reg ulations require that when marks include only the Roman capital letter “ N” and the registration nu mber is displayed on limi ted, restricted or light sport category aircra ft or experimental or prov isionally certificated aircr aft, the operator must also display certain terms near each entrance to the cabin, cockpit, or p ilot station, in letters not less than two inches o r more than six inches hig h. Here, the sUAS will n ot be issued an airworthiness certificate a nd there will be no cabin or cockpit upon which ce rtain words may be displayed. An equivalent level of safety for these e xemptions will be reache d by having the sUAS marked on its fuse lage where the pilot, obse rver, and others working with the sUAS will see the identification of th e sUAS as “Experimental ”. The Applicant will als o comply with any further requests for sUAS markings by the FAA.

14 CFR 61.113 Private pi lot privileges and limitati ons.- 5 -

#2451872v.1 The regulation provides t hat no person that holds aPrivate Pilot certificate m ay act as a Pilot in Command (“PIC”) of an aircraft for compensation or hire. Subpargraph (b) allows a private pilot to act as a PIC of an aircr aft in connection with any business or employment if the flight is incidental to that business or employment, and the aircraft does not carry pa ssengers or property for compensation or hire. Because the sUAS will n ot carry a pilot or passeng ers and is inherently stable with a sophisticate d computer and GPS con trols, the proposed operat ions meet the equivalent level of safety as the regulation by requ iring the PIC operating th e sUAS to have significant and extensive experience operating the sUAS in a non-commerci al environment. Furthermore, the area of o peration is controlled andrestricted, and all flights are planned and coordinated in advance ac cording to the User Manu al, and the flights are of l imited duration and altitude.

14 CFR 91.7 Civil Aircra ft Airworthiness.

No such airworthiness ce rtificate will be issued forthe sUAS and therefore t his regulation is inapplicable to the Applic ant’s sUAS. The Applica nt will ensure that the sU AS is in airworthy conditions based upon co mpliance with the operati ng documents prior to ev ery flight, and determine that the sUAS are in safe operational co ndition. Given the size o f the sUAS and the requirements contained in the User Manual for mai ntenance and use of safet y checklists prior to each flight, an equivalent level of safety will be pr ovided.

14 CFR 91.9 Civil Aircra ft flight manual, marking and placard requirements

. This regulation provides that no person may opera te an aircraft unless a cur rent, approved flight manual is in the aircraft. The applicant believes th e intent of this regulation is to ensure that flight manual information is available to the aircrew while operating the aircr aft. The Applicant requests an exemption be cause the aircraft to too s mall to carry the docume ntation, and the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of Se ction 91.9, the Applicant proposes that a User Manual be made availabl e to the crew at the groun d station anytime the airc raft is in or preparing for flight.

14 CFR 91.103 Preflight Action

The Application seeks an exemption from 91.103, which requires a PIC to b ecome familiar with specific information befo re each flight, including i nformation contained in t he FAA approved Flight Manual on board t he aircraft. An FAA appr oved Flight Manual will n ot be provided for the sUAS, and therefore a n exemption is required. An equivalent level of saf ety will be provided by following the sUAS M anual’s comprehensive pr eflight checklist. The PIC will take all actions, including review ing weather, flight batteryrequirements, landing an d takeoff distances, and aircraft performance data, before initiation of f light.

14 CFR 91.119 Minimum Safe Altitudes.

The regulation establishe s safe altitudes of civil air craft and states that the m inimum safe altitude requirements under which an aircraft may not opera te, include 500 feet above the surface and away from any person, ve ssel, vehicle or structure i n non-congested areas. S ection 91.119(d)(1) allows for a helicopter to operate at less than those altitudes when it can be o perated without- 6 -

#2451872v.1 hazard to persons or prop erty on the surface, provi ded that each person oper ating the helicopter complies with any routes or altitudes specifically p rescribed for helicopter b y the FAA. To provide the intended phot ography and inspections t he sUAS will normally ne ed to be operated within a range of between 50 and 200 feet from the property being filmed or photographed, and therefore an exemption is required. The Applicant submits that an equivalent level of safety may be achieved because oper ations will only be flown over property or persons where permission has been obtained and car eful pre-planned flight pa th has been performed. T he aircraft will be operated at a low altitude allowing, if the power fa ils, for an emergency land ing without undue hazard to persons or prop erty on the surface. Base d on the small size of the UAS, the hazard to persons, vehicles and stru ctures is limited when com pared to manned aircraft, which should be considered in granting the exception.

14 CFR 91.121 Altimetersettings.

This regulation requires t hat aircraft shall maintain cruising altitudes by refe rence to an altimeter setting available within 1 00 NM of the aircraft. Th e sUAS will always fly b elow 400 feet above ground level (“AGL”) an d will not need to maintai n cruising altitudes in ord er to prevent conflict with other aircraft. An eq uivalent level of safety w ill be achieved by followi ng the procedures set for in the User Manua l, and the PIC will use the GPS altitude indicator to constantly monitor the sUAS height, thus ens uring operation at safe alt itudes.

14 CFR 91.151 Fuel Req uirements for flight in VF R Conditions.

The regulation provides t hat no person may begin a flight in an airplane und er VFR conditions unless there is enough fue l to fly to the first point o f intended landing and to fly after that for at least 30 minutes, or if in arotorcraft for at least 30 minutes. The Applicant b elieves that the intention of this paragrap h is to provide an energy reserve as a safety buffer for delays to landing. The battery powering the sUAS provides for appro ximately 23 minutes of p owered flight. An equivalent level of safety can be achieved by limit ing flights to 20 minutes or 25% of remaining battery power, whicheverhappens first. This restri ction would be more than adequate to return the sUAS to its planned l anding zone from anywhe re within its limited opera ting area. Operation of the sUAS with less tha n 30 minutes of reserve fu el does not engender the t ype of risks that. Moreover, operation will be limited to controlled a reas where only people an d property owners or official representative who signed waivers will be allowed. Based on the se considerations an equivalent level of safety will be ensured.

14 CFR 91.203(a) & (b) C ivil Aircraft: Certification s Required.

The regulation provides t hat an airworthiness certi ficate, with the registratio n number assigned to the aircraft and a registra tion certificate must be ab oard the aircraft. Additio nally, subparagraph (b) provides that the airw orthiness certificate be “d isplayed at the cabin or co ckpit entrance so that it is legible to passen gers or crew.” Here the s UAS is too small to carry documentation, does not have an entrance , and is not capable of car rying passengers or crew. To obtain an equivalent level of safety and meet the intent of Se ction 91.203, the Applica nt proposes that documents deemed appro priate for the sUAS be wi th the crew at the ground control station and available for inspection u pon request. In order to i dentify the aircraft, we pr opose that the information found on airw orthiness and registration certificates be permanently affixed to the- 7 -

#2451872v.1 aircraft view placard cont aining the following infor mation plus the word exp erimental to satisfy the requirement of 14 CF R 45.23.

14 CFR Subpart E, Sectio ns 91.401-91.417 – Main tenance, Preventive Maintenance, and Alterations

The regulation provides t hat the operator is primar ily responsible for mainta ining the aircraft in an airworthy condition, in cluding compliance with part 39 and 43. Paragrap hs 91.407 and 91.409 require that the ai rcraft be “approved for re turn to service by a perso n authorized under 43.7” after maintenance a nd inspection. It is the A pplicant’s intention that t he PIC perform maintenance and inspecti on of the aircraft and “be authorized to approve th e aircraft for return to service.” The PIC will en sure that the aircraft is in an airworthy condition pr ior to every flight and in addition conduct d etailed inspections after e very two hours of flight. Maintenance performed by the PIC is l imited to repairing small cracks, replacing a prope ller, checking electrical connections andupdating software and fi rmware for the on-board computer. All other maintenance will be perfo rmed by the manufacture r or their designated repa ir facility. The PIC will document work perfo rmed in accordance with 91.417. Due to the size, c onstruction and simplicity of the aircraft, the PIC can ensure an equ ivalent level of safety is r eached.

IV. Safety and Benefits o f the UAS to the Public as a whole

The Applicant will use th e sUAS in a variety of ap plications that generally r equire expensive and full-size manned aircraft to complete. Small, light , unmanned aerial vehicle s offer numerous benefits over the use of fu ll-sized manned aircraft f or real property inspectio ns, and event film and still photography. Th e safe operation of sUAS will allow a wider range of individuals to obtain the benefits of aeri al photograph, at a manag eable and reasonable cost . The public as a whole will benefit from t he safer and more cost-ef fective availability of aer ial photography. Replacing larger mannedaircraft carrying crew an d flammable materials wi th small UAS carrying no passengers orcrew provides increased safety for pilots and crew . By granting the Applicant’s requested exe mptions, the FAA will as sist with the development and safety of commercial sUAS operat ions. Therefore, the FAA has good cause to grant t his application.

V. A Summary for Pub lishing in the Federal Re gister

Annapolis Drone Operati ons, LLC seeks an exemp tion from the following ru les:

14 CFR Part 21; 14 CFR Part 27; 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 CF R 91.109(a); 14 CFR 91.1 19; 14 CFR 91.121; 14 CFR 91. 151(a); 14 CFR 91.203(a ) & (b); 14 CFR 91.405(a ); 14 CFR 91.407(a)(1); 14 CFR 91. 409(a)(2); 14 CFR 91.417 (a) & (b).

Annapolis Drone Operati ons, LCC seeks this exem ption for the purposes of conducting aerial photogr aphy, videography and in spections for commercialand residential real estate, leg al, construction and insur ance industries, and event photograph and videography.

Annapolis Drone Operati ons, LLC does not intend to operate the sUAS outs ide of the United States.- 8 -

#2451872v.1 VI. Conclusion.

As set forth herein, Annapolis Drone Operations, L LC seeks an exemption p ursuant to 14 CFR 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation of the DJI Phantom 3 UAS commer cially, without an airwort hiness certificate, for the limited purpose of co nducting aerial video andphotography over certainareas of the United States. By granting this P etition, the FAA Adminis trator will be fulfilling th e Congressional mandate of the FAA Mod ernization and Reform Ac t of 2012 while also adva ncing the interest of the public, by allowing th e safe, efficient and econo mical operation of the DJ I Phantom 3 UAS commercially within the NAS.

Dated: July 8, 2015

Annapolis Drone Operati ons, LLC

_____________________________________ Andrew Steven Watmoug h, Managing Member 947 Old Annapolis Neck Road Annapolis, Maryland 214 03 443-822-6130 annapolisdroneops@gma il.com