JULY 12 2015

U.S. DepartmentofTransportation Docket Management System 1200 New JerseyAve., SE Washington DC 20590

Petition ofGreg Nelson's for Exemption Pursuantto Section 333 ofthe FAA Modernization and Reform Act 2012

Dear Sir and or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 11, Greg Nelson hereafter referto as petitionerhereby applies for an exemption from Federal Aviation Regulations (FARs) details below for the Phantom 3 Professional here after referred to as UAS. Attachments; References 1.Phantom 3 User Manual 2.Phantom PilotTraining The Petitioner requests exemption from the following sections ofTitle 14 Code of Federal Regulations: 814 CFR 61.103, 61.113a, 61.113b, 91.119c, 91.121, 91.151a,b 91.405a, 91407a1, 91.409a1, 91.409a2, 91.417 a+b,

This exemption would provide commercial operation ofUAS craftby the petitioner in airspace regulated by FAA to provide aerial surveying, aerial photography, real estate surveying, crew membertraining, news gathering, fire, rescue, scientific air quality evaluation in hazardous conditions, and mapping services. The FAA's approval ofthis application will supportvarious industries, benefit the environment, and build a newbusiness model, all ofwhich are in the public interest. Operations are to be completed only atthe requestofclients with their full permission to facilitate commerce and awareness ofthebenefits ofUAS craft. The petitioner's operation underthe exemption is subjectto strictoperating requirements and procedures to ensure the highest safety standards at all times. Following outlined procedures ofattachments 1-2.0perations are within and under the control outlined herein oras maybe established by the FAA under section 333. 

# (I)Exemption from the the following FARs is requested for the following reasons: 814 CFR 91.103 PREFLIGHT Petitionerrequests reliefdo to the fact thatDJI's UAS craft do nothave published approved Airplane or Rotorcraft Manual containing takeoffand landing distances. It can be said they operate below 400 feet. They follow preflight actions outlined in attachments 1,2. 814 61.113a; 61.113b The Petitioner requests exemption to benefit the utilization ofpilots who hold a sports certificate orgreater. Any pilots operating underthis exemption are required to comply with any all conditions as setforth in previously granted exemptions. 814 91.119c The Petitioner requests an exemption to operations closer than 500 feet as UAS craft are supposedto fly below 400 feet. They need this exemption to allow for reasonable and responsible operations in areas ofsubdivisions and neighborhoods and otherareas ifrequired. As set forth in the Operations Manual, the UAS craftwill be operated in a safe and uncongested area, where buildings and people will notbe flown nearwithout theirpre-obtained consent. This allows for property owners, participants, and all affected individuals to be aware ofplanned flight operations. The DJI UAS demonstrates thatthey can be safely used atthese lower altitudes and closer environments to do thejob they are intended for.

814.121 Petitionerseeks exemption due to fact thatUAS craft uses a GPS for altitude indication. Barometric pressures are not used in a UAS craft. 814 CFR 91.151a,b Petitionerrequests exemption as UAS craft uses batteries for fuel and has a total flight limitation ofabout 20 minutes due to this fact. Therefore they cannot meetthe reserve requirementfor this section. Given the UAS craft flight duration proposed flight plans for these UAS craft mustconform to a flight area and safety margin within theirlimitations. Abattery alarm is in place, which indicates when the UAS craft mustland to stay within its safety limitation for flight duration. 

# ('J.)814 CFR 91.405a, 91.407al, 91.409al, 91.409a2, 91417a, 91417b Petitioner seeks exemption as the UAS craft inspections to insure safe operations are included in the attachments 1,2. These operating documents provided by petitionerdescribe the conditions, limitations and requirements for maintenance, inspection, and properrecord keeping. These are adequate to ensure that safety is foremost and maintained 100 percent. UAS Craft DJI Phantom 3 Professional The requested exemption would allow precise commercial operation ofthe petitioners UAS Craft. These craftweightbetween 5 and 20 lbs. with a top speed of under 80mph with presetceiling of400 feet allow for precision services to perspective clients. Preforming invaluable services thatlarger conventional fix wing and rotational craft simply cannotpreform as efficiently. These UAS Craft can preform precision aerial surveying, aerial photography, real estate surveying, crewmembertraining, newsgathering, fire, rescue, scientific air quality evaluation in hazardous conditions, and mapping services. They also reduce fuel emissions providing environmental benefits. Flight operations underthe 333 exemptions are subjectto strictrequirements and rules to insure an equal level ofsafety to current authorized operations using manned aircraft. These conditions maybe modified by the FAA as required by the 333 Exemption. The UAS Crafts will atlow altitude under400 feet, 5 miles away from any airport, and in accordance with procedures and rules laid down in attachments 1,2. The UAS Craftwill utilize control features conforming to prescribed limitations. The UAS Craft will operate in air space approved by the FAA. The UAS Crafts will be operated by a pilotin control known as PIC. PIC will hold a minimum Sports Certificate and a valid drivers license. PIC will operate UAS Craft with a clear line ofsight ofthe UAS Craft with no visual aids other then prescription eyeglasses. In addition to the PIC flying the craft a visual observer known as the VO mustbe presentwhile the UAS is flying to insure safety looking out for where the PIC is flying. The PIC and VO mustbe within speaking distance atall times during the flight. Enhanced safety and the fulfillment ofthe FAA Administrator's responsibilities underSection 333c ofthe reform Act to" established requirements for the safe operation ofsuch aircraft systems in the national airspace system" will be moved forward with approval ofthese exemptions. 

# (?)FAA exemptions references 1-2. Conditions and Limitations Section will be used in orderlimit risk and enhance public safety. Preflight checklistwill be used to ensure thatthe UAS Craft's airworthiness will be maintained priorto each launch. Public Operation The use ofUAS Craft compared to manned aircraft for these operations (aerial surveying, aerial photography, real estate surveying, crew membertraining, news gathering, fire, rescue, scientific air quality evaluation in hazardous conditions, and mapping services) will enhance safety and lead to economic growth. The UAS Craft can simply do work thatmanned aircraftcannot do in many specific circumstances. The Petitioner will provide these services acting as an independentcontractor. Providingjobs for certified Pilots and visual observes as both will be used to complete services. Liability insurance has been applied for and will be in effect when this Exemption is granted. Information can be submitted to FAA COA monthly reports orby any othermeans required orrequested. The Petitioner wants to be a responsible participantin this new industry and sees a tremendous need for these services. The petitionerprays thatthis 333 Exemption be granted so thatthe Petitioner may go to workunder the rules and regulations ofthe FAA. Conclusion The Petitioner is requesting 333 Exemption for the following services: aerial surveying, aerial photography, real estate surveying, crew member training, news gathering, fire, rescue, scientific air quality evaluation in hazardous conditions, and agricultural spraying theycan be rendered safely saving money and may even save life. The objective ofPetitioner is to provide these services safely, efficiently, and legally to enhance the clients needs. The Petitionerhas over 30 years ofexperience in robotics. Petitioner also has certified Pilots within ourgroup. Iwill be enrolled in flying lessons September2015. Sincerely and respectfully



# -~~ Greg Nelson 843 3648900 4466 Hope Plantation Dr. Johns Island SC 29455'---/



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