Russell J. Ullrich July 8 th , 2015 466 I sle Roy ale Rd Galesburg, IL 61401 Cell (309) 335 7300 Email: ullrichr@gmail.com

U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: 1) 3DR Solo User Manual 2) 3DR Solo (safet y notes) 3) 3DR Solo Altitude L imit document 4) 3DR Solo training guide 5) Flight L og 6) exemption/rulemaking

Re ferences: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

– 2014

– 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYI NG CAM INC

Dear Sir or Madam, In accordance with the FAA ’ s Guidelines for Submitting a Petiti on for Exemption under section 333 of the FAA Modernization and Reform Act of 2012 , I Russell J. Ullrich

, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§

**61.113(a) ;**  **61.113(b) ;**  **91.119(c) ;**  **91.121 ;**  **91.151(a) ;**  **91.405(a) ;**  **91.407(a)(1) ;**  **91.409 (a)(1)**  **; 91.409(a)(2)**  **; 91.417(a) & (b)**  **;** In order to operate small unmanned aircraft s ys tems (UAS) commercially in airspace regulated b y the Federal Aviation Administration (FAA ) for the purposes of aerial photograph y, cinematograph y, videography

, and other flight operations that could be performed safel y and more cost effectivel y with the use of small UAS at low altitude within the U.S. national airspace
sy stem as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air s ys tems.So long as such operations are conducted within and under the conditions outlined herein

or as may be established by

the FAA as required by

Section 333. The conditions identified and proposed b y the petitioner are drawn from references 1

- 3.

**The FARs** The petitioner seeks exemption from the above mentioned FARs for the following

reasons ; **61.113(a) & (b)** ; The petitioner requests relief in order to facilitate the utilization of an experienced UAS operator with the a ddition of a trained observer. All pre

- flight inspection, maintenance and flight logs will be saved and made available to the FAA an d Secretary of Transportation (SoT) for review ; with the purpose of safel y integrating civil UAS operation in the National A irspace Sy stem

. **91.119(c)** As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible witho ut additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “ congested areas ” and

“ densely populated ” . The petitioner requests waiver for this condition to allow reasonable and responsible operatio ns in areas of subdivisions and neighborhoods if required. The petitioner will primarily operate the UAS between ground level and 200 feet. The UAS will be operated over designated properties with the owner’ s consent and while maintaining a safe distance from persons. The petitioner will compile flight data from the logs. This data may assist the FAA in development of regulations for commercial operations in low

- risk, controlled environments. **91.121** As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is in applicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. **91.151(a)** As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for day time, VFR conditions. The UAS provides batt ery power remaining in percent to the PI C. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a

con dition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum power reserve for f light in day

time VFR conditions was reasonable. **91.405(a) ;**  **91.407(a)(1) ;**  **91.409 (a)(1) & (2) ;**  **91.417(a) & (b)** As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight i n accordance with the operating documents. The FAA found that adherence to the petitioner’ s operating documents and theconditions and limitations specified, describing the requirements for maintenance, inspection,

and recordkeeping, were sufficient to ens ure that safet y would not be adversely affected.

**The UAS** The 3DR Solo is a highl y successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to

carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning sy stem (GPS) to maintain its geospatial orientation and position. It is controlled primaril y through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PI C to monitor battery

level, GPS signal strength, altitude (AGL), distance from PI C, camera imagery , and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed b y the PI C. Battery life limits flight times to approximately 25 minutes. The onboard fl ight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery

state. An automatic termination of flight and landing will be initiated when the battery

reaches a predetermined low state. It is anticipated that fl ights will usually last less than 12 minutes. More information is available in attachment 1

.
**Risk mitigation** The petitioner has reviewed FAA exemptions reference ’ s 1

- 3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safet y. A preflight checklist will be developed and employ ed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components. These documents will be made available to the FAA and SoT to assist in future implementation of safet y standards and regulations. The petitioner will only operate the UAS over designated properties with the owner’ s consent. Flight plans will be predetermined to limit the UAS s flight time and limit safety

concerns. The petitioner will take into account distance from pers ons and potential flight obstacles prior to operating the UAS. UAS operation will alway s be within VLOS of the PI C and the observer.

**Public interest** Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally , use of the UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for propert y owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be display ed through ground level videography /photography . Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography . Aerialsurveying and inspections can increase work site efficiency , improve volumetric estimations and

reduce risks. The petitioner will provide clients with ph otographic data for these purposes on a

‘ for hire ’ basis acting as an independent contractor. A visual observer will be utilized. Flight data including UA flight time, Control Unit operation time, incident, accident, and details concerning
any deviations f

rom normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via traditional means or other means as required.

**Conclusion** The petitioner is requesting th is exemption for the purposes of “ aerial photograph y, cinematograph y, videography , inspections and other flight operations ” . The reason for such a general and broad based request is that the petitioner wishes to utilize a business strateg y of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptions. The petitioner's business model is based on the id e a of offering ad hoc small UAS services to individuals or companies who wish to e mploy these services as a safe, effective, and legal option to enhance their business or hobb y. The petitioner has refrained from engaging in commercial use of the UAS. The pr imary purpose of seeking this exemption is to obtain the capability to offer th ose services while remaining in compliance. The petitioner has 5 ye ars of experience in the radio control model aircraft hob by

. Respectfully

submitted

Russell J. Ullrich