United States Department ofTransportation Docket Management System 1200 NewJerseyAve., SE West Building Ground Floor Room W12-140 Washington, DC 20590 , I

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Re: Exemption Request Pursuant To Section 333 ofthe FAAReformAct of2012

Dear Sir or Madam: I am writing pursuantto the FAAModernization and ReformAct of20121 (the "ReformAct") and the procedures contained in 14 C.P.R. 11, to request that I DavidArsenault, an owner and operator ofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listedbelow so that DavidArsenault, may operate unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal AviationAdministration ("FAA"); as long as such operations are conducted within and under the conditions outlined herein or as may be established bythe FAAas required by Section 333. The conditions ofuse identified and proposed by the applicant are: 1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, and news gathering. 3. Aerial inspection/photography ofresidential/commercial structures under contract with the owners or local government authority. · · 4. Aerial inspection/photography ofresidential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and communication towers. 5. Aerial video/photography orproviding live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster only whenthe local authorities or government has requested 

### it by contract or donation. 6. UAS Training to persons individually orbelonging to the CivilAir Patrol and/orprivate and public organizations to increase awareness and improve safety for current and future UAS operations within the national air space. As identified and described herein, I DavidArsenault, an FAAprivate pilot, recognized FCC radio technician and a avid RC model operator for overthirty five (35) years, would only enhance and promote, safe commercial operation's ofUAS within the national air space. Furtheimore, David Arsenault has rejected all offers to provide commercial operation ofany UAS services to date, within the United States, to ensure he is in compliance with any applicable FARs. Granting DavidArsenault's request comports with the Secretary ofTransportation's (FAA Administrator's) responsibilities to not only integrate UASs into the national airspace system, but to "

... establish requirements for the safe operation ofsuch aircraft systems [UASs] in the national airspace system" under Section 333(c) ofthe ReformAct. Further, David Arsenault will conduct its commercial UAS operations in compliance withthe protocols described herein or as otherwise established by the FAA. 1DavidArsenault respectfully requests the grant ofan exemption allowing itto operate lightweight, remote controlled UAS's. The Specific Sections ofTitle 14 ofthe Code ofFederal Regulations, DavidArsenault Requests Exemption are: · 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR407 (a)(l); 14 CFR409 (a)(2); and, 14 CFR 417 (a) & (b). Exemption Request Section 333 ofthe FAAReformAct and Part 11 ofthe FederalAviation Regulations from 14 C.F.R. 45.23(b);14 CFRPart 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). The Extent of Relief DavidArsenault Seeks and the Reason It Seeks SuchRelief: DavidArsenault submits this application in accordance with the ReformAct, 112 P.L. 95 §§ 331-334, seeking relieffrom any currently applicable FARs in order to operate a YUNEEC Q500 and a DJI PHANTOM 3 for contemplated commercial, research and other flight operations withinthe national airspace system. The ReformActprovides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is inthe public's interest to do so. DavidArsenault's lightweight UASs meet the definition of "small unmanned aircraft" as deemed in Section 331 and therefore the integration of DavidArsenault's lightweight UASs are expressly contemplated by the ReformAct. DavidArsenault would like to operate lightweight UASs priorto the time period by whichthe Reform Act requires the FAA to promulgate rules governing such craft. The ReformAct guides the Secretary in determining the types ofUASsthat may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS; Whether the UAS will be operated near airports orpopulated areas; and, Whether the UAS will be operatedbyline ofsight. 112 P.L. 95 § 333 (a). Each ofthese items militates in favor ofan exemption for DavidArsenault. DavidArsenault UAS's utilizes four counter-rotating propellers for extreme balance, control and stability. They each weigh less than 55 pounds, including equipment. Each ofDavidArsenault's small unmanned aircraft are designed to primarily hover inplace and operate at less than a 40 knot maximum speed. They are capable ofvertical and horizontal operations but operate only withinthe line ofsight of the pilot in command. Utilizing battery power, flights generally last between five andtwenty minutes. Safety systems inplace include a GPS mode that allows DavidArsenault to hover inplace ifcommunication with the radio control pilot is lost and then slowly descend the UAS. Further, the UAS could be programmed, in some instances, to slowly follow the pilot command Utilizing the onboard GPS system. The UAS operating software and GPS navigation systems do not allow any of DavidArsenault's UAS aircraft to operate near airports orrestricted fly zones. The fail-safe software will disable the UAS vehicles from taking offand also limitthe UAS systems from operating within specific GPS preset no-fly zones. Furthermore, DavidArsenault will comply with all TFR's, operation ofsmall unmanned aircraft will not "create a hazard to users ofthe national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). 2Given the small size and weight ofthe UASs, combined with their operation in cordoned offand wellcontrolled areas, DavidArsenault fleet falls within Congress's contemplated safety zone when it promulgatedthe ReformAct and the corresponding directive to integrate UASs into the national airspace system. The FAAhas the authority to issue the exemption to DavidArsenaultpursuant to the FederalAviation Act, 85 P.L. 726 (1958),**a~** amended (the "Act"). Commercial and Public Benefits Granting David Arsenault this exemptionrequest furthers the public interest. First, Congress has already pronounced that it is in the public's interest to integrate commercially flown UASs into the national airspace system, hence the passing ofthe ReformAct. Second, as a pilot DavidArsenault promotes and encourages safe UAS operations every time one of his UASs takes flight. Third, the public has an interest inreducing the danger and emission associated with current aerial video capture methods, namely, full size helicopters. DavidArsenault's UASs are battery powered and create no emissions. IfanUAS crashes no fuel would ignite orexplode. The impact of lightweight UASs is far less than a full size helicopter. Congress mandated the integration ofUASs into ournational airspace system, inpart, to achieve progression inthis noteworthy, and inevitable, field. Permitting DavidArsenaultto immediately fly within the United States furthers these goals. Reasons Why Granting DavidArsenault an ExemptionWill NotAdverselyAffect Safety OrHowThe ExemptionWill Provide a Level ofSafetyAtLeast Equal To Existing Rule: Permitting DavidArsenault to log more flight time in FAA controlled airspace will allow innovation and implementation of new and as ofyet undiscovered safety protocols. In addition, DavidArsenault submits the following representations ofenhancements to current aerial video capture methods.

• UASs weigh less than 55 pounds.

• DavidArsenault only operates its UASs below 400 feet.

• UASs only operate for 5-25 minutes per flight

• The pilot in command operates UASs by line ofsight

• UASs have GPS flight modes whereby they hover and then slowly land ifcommunication withthe remote control pilot is lost.

• DavidArsenault actively analyzes electronic flight data and other sources ofinformation to constantly update and enhance safety protocols.

• DavidArsenault is a licensedpilot. UASs carry no people onboard and DavidArsenault operates them in specific areas away from mass populations. Lastly, giventheir small size and weight, even when close enough to capture amazing images, UASs need not be so close to the objects they are focused on. 3A Summary The FAA May Publish inthe Federal Register: A. 14 C.P.R. 21 and 14 C.P.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.P.R. 21, Subpart H, entitledAirworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates inrelation to FAR§ 91.203(a)(l). The size, weight and enclosed operational area of UASs permits exemption from Part 21 because UASs meet an equivalent level of safetypursuant to Section 333 ofthe ReformAct. The FAAis authorizedto exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 ofthe Reform Act. Bothpieces oflegislationpermitthe FAAto exempt U ASs from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. DavidArsenault's UASs meet orexceed each ofthe elements. 14 C.F.R. 91.7 (a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the F ARs, this Regulation is inapplicable. 14 C.P.R. § 91.9 (b) (2) requires an aircraft flight manual inthe aircraft. As there are no pilots or passengers, and given the size ofthe UASs, this Regulation is inapplicable. An equivalent level of safety will be achieved bymaintaining a manual at the flight operations center. The FAAhas previously issued exemptions to this regulation in ExemptionNos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.P.R. § 91.121 regarding altimeter settings is inapplicable insofar as UASs utilize electronic global positioning systems and internal gyroscopes to provide spatial coordination. 14 C.P.R.§ 91.203 (a) and (b) provides for the carrying ofcivil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level ofsafety will be maintained by DavidArsenault. B. 14 C.P.R. § 45.23: Marking ofTheAircraft. Applicable Codes ofFederal Regulation require aircraft to be marked according to certain specifications. UASs are, by definition, unmanned. They therefore do nothave a cabin, cockpit orpilot station on which to mark certain words orphrases. Further, two-inch lettering is difficult to place on such small aircraft. Regardless, DavidArsenault will ma;k its UASs inthe largest possible lettering. The FAAhas previously issued exemptions to this regulation through ExemptionsNos. 8738, 10167, 10167 A and 10700. C. 14 C.P.R. § 61.113: Private Pilot Privileges and Limitations: Pilot In Command (PIC). Pursuant to 14 C.P.R.§§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. DavidArsenault can achieve an equivalent level ofsafety as achieved by current Regulations because UASs do not carry any pilots orpassengers. Further, the risks attendantto the operation ofUASs is far less than the risk levels inherent inthe commercial activities outlined in 14 C.P.R.§ 61, et seq. Thus, allowing Network Media Services to operate its UASs with a private pilot license as the pilot in command will exceed current safety levels inrelation to 14 C.P.R. §61.113 (a) & (b) 4D. 14 C.P.R. 91.119: Minimum Safe Altitudes. 14 C.P.R. § 91.119 prescribes safe altitudes for the operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. David Arsenault will never operate at an altitude greaterthan 400 AGL. E. 14 C.P.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above-cited Regulations require, amongst otherthings, aircraft owners and operators to "have [the] aircraft inspected as prescribed in sub-partE ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed inpart 43 ofthis chapter." These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to DavidArsenault should its requested exemption be granted. David Arsenault conducts an extensive maintenance program that involves regular software updates and constant inspection for assessment ofany damaged hardware. Therefore, an equivalent level ofsafety will be achieved. F. Summary. I DavidArsenault plan to pilot a UAS, YUNEEC Q500 and a DJI PHANTOM 3 which is comprised ofan unmanned aircraft and a transportable ground station. Boththe YUNEEC Q500 and Phantom 3 is referred to as a quad-copter UAS, with a maximum gross takeoffweight ofabout 3 pounds each. Both are equ:pped with rotors that are driven by electric motors powered by batteries. The UAhas a maximum airspeed ofabout 16 m/s. DavidArsenault seeks an exemption from the following Regulations: 14 C.P.R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.P.R.§§ 61.113 (a) & (b); 14 C.P.R.§ 91.7 (a); 14 C.P.R.§ 91.9 (b)(2); 14 C.P.R. § 91.103(b); 14 C.P.R.§ 91.109; 14 C.F.R. § 91.119; 14 C.P.R.§ 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.P.R.§ 91.405 (a); 14 C.P.R.§ 91.407 (a)(l); 14 C.P.R. § 91.409 (a) (2); 14 C.P.R. § 91.409 (a)(2); and, 14 C.P.R.§§ 91.417 (a) & (b) to commercially operate its fleet of small unmanned vehicles and lightweight unmanned aircraft. Granting DavidArsenault request for exemption will reduce current risk levels and thereby enhance safety. David Arsenault respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by DavidArsenault pursuantto the FederalAviation Act, 85 P.L. 726 (1958), as amended (the "Act").

David M. Arsenault 153 McKishen Rd Pittsgrove NJ 08318 5