28 August, 2015

From:

Travis J Dziubla

945 Ohlone Ave, #963

Albany, CA 94706

(858) 353

- 2556

tdziubla@gmail.com

AMA Member: 1075199

FCC Callsign KK6TZN

Subject:

Petition for Exemption 14 CFR § 11.81

, Exemption petition under 14 CFR section 21 (§§

21.171

- 21.199) and SEC 333 of THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

The specific section or sections of 14 CFR from which you seek an exemption:

1. I petition for exemption from 14 CFR section 21; specifically SUBPART H

— Airworthiness

Certificates (§§ 21.171

- 21.199) as required for UAS operations for Civil Aircraft.

2. I also petition for Exemption under Sec 333 of THE FAA MODERNIZATION AND REFORM

ACT OF 2012 (PUBLIC LAW 112

- 95)

The extent of relief you seek and the reason you seek the relief:

Current FAA rules prohibit the use of a UAS for commercial purposes on private property and

UAS operations or Civil Aircraft without obtaining an FAA Airworthiness Certificate. I am seeking

reli ef of these requirements

, including obtaining an FAA Airworthiness Certificate. I am an

experienced UAS pilot and am simply petitioning for an exemption to provide a commercial

service to private land owners and companies who wish to obtain and capture Aer ial photos and

videos of said property for purpos es including

, but not limited to:

(1) real estate listings

(2) insurance property claims, and

(3) as a marketi ng tool for businesses

I would like to seek an exemption for the purposes of rende ring the above services in a

commercial setting, allowing me to set the foundation for a small business in the future while

also legally serving the community with a highly sought

- after service.How your request would benefit the public as a whole:

The Section 333 Exemption process provides operators who wish to pursue safe and legal entry

into the NAS a competitive advantage in the UAS marketplace, thus discouraging illegal

operations and improving safety. It is anticipated that this activity will result in significant

economic benefits, and the FAA Administrator has identified this as a high priority project to

address demand for civil operation of UAS for commercial purposes.

As noted above, the public sector currently places a high demand on UAS services for

commercial purposes. My exemption would benefit the public by providing customers with:

(1) a legally exempt pilot with 15 years of recreational UAS experience

(2) a platform for small business to grow and expand their operations

(3) a posit ive example of responsible UAS operation, thereby educating the public on safe use

By allowing me to serve my community with the requested exemption, we could begin to curb

the reckless and illegal use of commercial UAS by inexperienced operators, who are currently

serving a community that has been historically underserved in aerial photography.Reasons why the exemption would not adversely affect safety, or how the exemption would

provide a level of safety at least equal to the existing rule:

As a 15 year UAS veteran, former military officer, and licensed HAM operator, I have an

understanding and appreciation for potential risk to the safety of the public, therefore, I would

be a good candidate for exemption of 14 CFR section 21 (§§ 21.171

- 21 .199) and SEC 333

while not putting Air Safety in any additional risk.

The UAS I employ (a customized system based on the TBS Discovery Pro ) and for which I am

seeking exemption for has been built with numerous redundant safety features, including SAFE

technology, GPS navigation, and automatic Return to Launch features . When flying for this

commercial purpose I would be flying at a maximum altitude of 200’, greater than 5 miles from

a ny airport, and away from any people beyond myself (as PIC) and my safety observer (SO) . My

service in the Navy as an Air Safety/Maintenance Officer also means I understand the inherent

risks, and required mitigation techniques, to ensure proper aircraft o peration . I would not be

flying near disaster areas, sporting events, or high traffic areas including airports and freeways

, and I would pay attention to NOTAMs in order to ensure consistent compliance

.

Furthermore, all my UAS are custom designed and built by myself, meaning I fully understand

the aeronautical/electrical engineering required to operate UAS, as well as the physical and

operational abilities and limitations of the systems I employ. This means that the public can be

assured that no system will fail for lack of knowledge or understanding of the systems I employ.

My airframe uses the NAZA 2 Flight Controller, and as such I will be flying primarily in Mode 1:

Flight Mode

– GPS Attitude Mode (Default) I

This mode allows the UAS to lock on a ho me GPS position as a failsafe to prevent loss of radio

control of the UAS due to unwanted interference or loss of power. Also includes built in no

- fly

zones to restrict flight over airports, and other sensitive locations.

Please see Enclosure 2 for a fli ght safety checklist that I will utilize pre

- launch and post

- recovery

to ensure full compliance, as well as my SO guidelines to be reviewed prior to every flight.A summary we can publish in the Federal Register

—

I, Travis J. Dziubla, am seeking an exemption of 14 CFR section 21 (§§ 21.171

- 21.199) and

Section 333 of THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

rules. I am petitioning for an exemption to provide a commercial service to private land owners

and companies who wish to obtain and capture a erial photo graphy and videos of their property

for purposes of real estate listings, insu rance property claims, and for marketing of businesses.

As a 15 year UAS veteran pilot, former military Air Safety/Maintenance officer, and licensed

HAM radio operator , I have a thorough understanding and appreciation for potential r isk to the

safety of the public when operating UAS. With these qualifications in mind , I would be a strong

candidate for exemption in order to better serve the public.

The UAS I employ (a customized system based on the TBS Discovery Pro) and for which I am

seeking exemption for has been built with numerous redundant safety features, including SAFE

technology, GPS navigation, and automatic Return to Launch featur es. When flying for this

commercial purpose I would be flying at a maximum altitude of 200’, greater than 5 miles from

any airport, and away from any people beyond myself (as PIC) and my safety observer (SO). My

service in the Navy as an Air Safety/Mainten ance Officer also means I understand the inherent

risks, and required mitigation techniques, to ensure proper aircraft operation. I would not be

flying near disaster areas, sporting events, or high traffic areas including airports and freeways,

and I would pay attention to NOTAMs in order to ensure consistent compliance.

I appreciate the FAA’s consideration of this petition for exemption.Any additional information, views, or arguments available to support your request:

I intend to use the safety checklist in enclosure 2 to ensure 100% compliance with FAA

requirements, AMA gui delines, and insurance purposes.

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

state the reason.

I have no intention o f using this exemption outside the United StatesExhibit 1: UAS Specifications

UAS

Airframe TBS Discovery Pro

Motors: Turnigy 1000kV motors

Propellers: Graupner e

- P rop 9x3

Flight Controller: DJI Naza V2 + GPS

Battery: TBS 4s 4500mAH

VTx: Lumenier 600mW 5.8GHz

Rx: FrSky X8R 16ch

Tx: FrSky Taranis Plus+

Voltage Monitor: FrSky SmartPort LiPo Voltage Sensor

Max Weight at takeoff: 5.3lbs

Max Speed: 60MPH

Max Altitude: limited in Flight Computer to 200’

Max Range: Tested safely to 45db, 1mi (VLOS ends at 1mi)

Ground Station

Custom design, Immersion RC Duo 5800 VRx with

- 7dB Patch and

- 3dB RD antennasEnclosure 2: Flight Safety Checklist