May 25, 2015

Travis Bedell

Pacific Aerial Surveyors

7619 Canberra Way

Riverside, CA 92508

petition to the Federal Aviation Administration (FAA) for an exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption would allow Pacific Aerial Surveyors to operate the PHANTOM 2 Vision+ quad-copter unmanned aircraft system (UAS) to conduct aerial photography and videography for construction surveying purposes. A grant of exemption to petitioner would lower carbon imprints (in comparison to jet turbine helicopters currently used), risk of injury/death to pilots/ passengers aboard currently used jet turbine helicopters and those in proximity of it’s flight path, and total costs of projects by reducing amount of jet turbine helicopter flight time (directly benefiting certain Mello-Roos and property tax payers in surrounding area of project).

The petitioner supports his request with the following

information: The petitioner has provided the following information – contained in his petition and supporting documentation including: 1) Supplemental Response for Petition

Page of 1 5 (951) 990-6859

PacificAerialSurveyors@yahoo.com

7619 Canberra Way

Riverside, CA 92508 PACIFIC AERIAL SURVEYORS2) PHANTOM Flying Flow Chart V1.0 (Simplified Version), PHANTOM Quick Start Manual v1.7, PHANTOM Advanced Manual v.1.4, 3) PHANTOM 2 Vision+ User Manual 4) restricted areas map 5) Safety/Preflight Checklist (all hereinafter referred to as operating documents).

The FAA has organized the petitioner’s information into

these sections: 1) the unmanned aircraft system (UAS) and operating parameters 2) the UAS Pilot In Command (PIC), 3) Public Interest.

Unmanned Aircraft System The petitioner states he plans to operate a UAS, the PHANTOM 2 Vision+, which is comprised of an unmanned aircraft (UA or PHANTOM) and a transportable ground station. The PHANTOM is referred to as a quad-copter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 30 knots. Petitioner plans to operate the UA over various areas in Southern California to lower project costs, increase project safety, and lower the environmental impact. Petitioner makes the following representations of operational enhancements which he proposes to abide by to ensure this exemption will provide a level of safety at least equal to existing rules:

Page of 2 5• He will only operate in reasonably safe environments that are strictly controlled, are away from airports and actively populated areas. All operations are conducted during daytime Visual Flight Rules (VFR) conditions and within visual line of sight (VLOS) of the pilots; and • He will conduct extensive preflight inspections and protocols, during which safety carries primary importance. The petitioner states that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by him, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333). Petitioner requests an exemption from § 45.23 Marking of the aircraft because his UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, he states that two-inch lettering is difficult to place

on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, petitioner states that he will mark his UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that he or anyone assisting him as a spotter will see the markings. The petitioner states that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. However, the petitioner states as a safety precaution he will perform a preflight inspection of his UAS before each flight as outlined in his operating

documents.

Page of 3 5UAS Pilot in Command (PIC) The petitioner asserts that under § 61.113 (a) and (b) private pilots are limited to non commercial operations, however he can achieve an equivalent level of safety as achieved by current regulations because his UAS does not carry any pilots or passengers. Further, he states that, while helpful, a pilot license will not ensure remote control piloting skills. He further indicates that the risks of operating a UAS are far less than the risk levels

inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus he requests an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in

command. Regarding UAS operational training, the petitioner states he has flown numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of his UAS’ performance under different temperature and weather conditions. He further states that he practices computerized simulated flights to maintain adequate skills and response reflex time.

Public Interest Environmental; Aircraft engine exhaust consists mainly of N2, O2 (oxygen), NOx, CO2, H2O (water vapor), CO, UHC (unburnt hydrocarbons), soot, and SOx (oxides of sulphur). NOx are combustion by-products while CO2 and H2O are the final products of the combustion process. The considered UAS produces zero of these emissions, directly benefiting surrounding publics air quality.

Page of 4 5Surrounding public can also be affected by noise pollution

benefits. Safety; Safety is of large concern on every construction project. Lowering the possibility of death/injury by utilizing the considered UAS in comparison to jet turbine helicopter directly affects publics interest. Costs; Reduction of total project costs by applying the considered UAS instead of jet turbine helicopter can benefit local property tax payers. Petitioner states that even indirectly, the cost savings of the UAS are in the publics interest.

In a supplemental request to the FAA, the petitioner requests consideration of a "blanket" COA for flights at or below 200 feet, or a 120 day temporary airman certificate in accordance with § 63.13, to allow the FAA time to

establish minimum UAS airman certification standards.

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