September 07, 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

- 0001

Summary:

Request for exemption from provisions to allow the use of small unmanned aerial systems on land controlled by self for aerial photography and videography, event photography and videography and real estate photography and videography

I, JohnPaul Cloutier, respectfully request an exemption from several provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial system (sUAS) for the use of aerial photography and videography, event photography and videography, and real estate photography and videography.

Contact Information

If there are any further questions regarding this request for exemption, please contact me using

the contact information below:

Name: JohnPaul Cloutier Mailing Address: 6 Mallory Court

Bristol, RI 02809

Phone: 401.465.6682

email: jpcloutier16@gmail.com

The Extent of relief you seek and the reason you seek the relief;

Section 333 prohibits the use of Unmanned aircraft system (UAS) for commercial purposes on private property. I am s eeking an exemption to provide a commercial service to real estate professionals, private landowners, private event coordinators and companies who wish to obtain and capture Aerial photo and videos of said property for purposes including real estate listin gs, insurance property claims, and for the use as a marketing tool for businesses as well aerial photography and video of special events.

How your request would benefit the public as a whole;

I am seeking this exemption to serve the public as a whole by providing an opportunity for small business owners, real estate professionals and others who may wish to benefit from aerial photography and videography for marketing or personal use.

The rea sons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek the exemption;I have read, therefore understand the importance of diff erent uses and safety concerns

regarding FAA regulated airspace, and would not put air safety in any risk. When flying for this commercial purposes I would be flying at a maximum height allowed by the FAA. As the Pilot In Command (PIC), I would at all ti mes keep visual contact between myself and the UAS knowing the location at all times. I would also be able to scan the airspace at which it is operating to see and avoid all other air traffic or objects aloft or on the ground. UAS will only be operated i n safe environments that are strictly controlled and away from disaster areas, sporting events, high pedestrian or vehicle areas putting any person or persons in any risk of injury. UAS, at all times, will be flown within the guidelines of manufactures rec ommendations. Preflight inspections of UAS will always be performed to ensure that UAS is found to have no defects.

If you want to exercise the privileges of your exemption outside the United States, you must state the reason;

I have no intention on usi ng this exemption outside the United States.

The Specific section or sections of 14 (C.F.R.) from which you seek an exemption;

I believe an exemption from the following provisions to conduct the operations mentioned in this request are required. To the extent that the FAA believes that additional relief is required to conduct the operations described here, we request an exemption from such regulatory provision

as well.

14 C.F.R. §91.119 Minimum safe altitudes: General

The only relief from this section i s from the minimum altitudes listed in paragraph c. Relief is required is for fixed wing operations because operations conducted at 500 feet or higher is found to inappropriate for the current use of the UAS. Since operations at this altitude also pose a heightened risk of collision safety can only be assured through the grant of an exemption.

14 C.F.R. §91.121 Altimeter settings As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equival ent level of safety will be achieved by the operation (PIC), pursuant to the user manual and Safety checklist, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. §91.151 Fuel requirements for flight in VFR conditions Operating the UAS in a pre

- defined area with less than 30 minutes of reserve fuel does not raise the type of risk outlined in §91.151. I do not intend to use the UAS for point

- to

- point flights and will not operate the UAS beyond visual line of sight, nor will the UAS require an airport in order to land. I believe that a 25% battery reserve is more than sufficient to meet this objective.

14 C.F.R. §91.405, §91.407, §91.409 Maintenance and Inspections I believe an exemption from these requir ements is appropriate since there are no known maintenance and inspections standards for UAS at this time.

14 C.F.R. §Any additional information, views or arguments available to support your request;

I, as Pilot in Command, have flown numerous flight in remote areas as a hobbyist simulating flight for future commercial use to gain familiarization with the characteristics of his UAS performance under different temperature and weather conditions. As a s afety precaution, I will perform a preflight inspection of the UAS before each flight as outlined in the User Manual. My intent is to only fly in non

- populated, residential or rural areas and stay clear of all utility lines, and other dangerous obstacles. I intend to be fully aware of my surroundings at all times and to fly the unmanned UAS within visual line of sight and only in visual flight conditions.

I intent to follow all suggested safety regulations as listed, but not limited to below;

● Intelligent flight battery safety guidelines will also be followed.

● Phantom 3 Safety Guidelines

● Pre

- flight checklist will be performed according to Manufacturer's guideline.

● Always keep UAS in sight and under control.

● All flight limites and No

- Fly Zones will be floo wed.

● Owner's manual flight environment requirement will be followed at all times.

● Keep children out of the vicinity of the UAS.

● UAS will be kept clean and carrefour when not in use.

● Batteries will be removed when not in use.

● UAS will never be operated

I understand and will comply with all health and safety regulations for PICs and will be the only operator under this exemption.

Attachments;

● Phantom 3 Safety Guidelines Disclaimer

● Intelligent Flight Battery Safety Guidelines

● Phantom 3 User Manual

Unmanned Aircraft System (UAS) of use;

Phantom 3 is DJI quadcopter and is capable of capturing 1080p video and captures 12 megapixel photos.. The UAS uses GPS signalling, and when unavailable Vision Positioning System will allow the UAS to hover accurate ly in place.

Weight: (Battery & Propellers): 1,280g (2.82 lbs) Diagonal Size (including Propellers): (23 inches) Maximum Speed: (35 mph)
GPS Mode: GPS/GLONASS Operating Frequency: 2.400 GHz

- 2.483GHz Battery: 6000 mAh LiPo 2S Working Voltage: 1.2 A @ 7.4V Transmitter Power (EIRP): FCC: 20dbm; CE: 16 dbm

This device complies with part 15 of the FCC Rules and FCC radiation exposure limits.Respectfully submitted,

JohnPaul Cloutier