January 25, 2016 U.S. Department
of Transportation Docket Management System 1200 New Jersey Ave., SE Washing ton,DC 20590 Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations. Name and Address of Petitioner: Jody Rosser 390 Texas Highway 43 Atlanta, TX 75551 903-276-9004 (Cell) thejrosser@gmail.com Dear Sir orMadam: Pursuant
to Section 333 of the FAA Modernization and Reform Act of 2012 (the

" Reform Act") and 14 C

.F.R

.Part 11, Jody Rosser, the Petitioner, request exemption from the following Federal Aviation Regulations

in order to legally operate anUnmanned Aircraft System (UAS) in the National Airspace System. Regulations from which the exemption

is requested

: 14CFR 21 H 14 CFR 45

.23 (b) 14 CFR 61

.113 (A) 7 (b) 14 CFR 91

.7 (a) 14 CFR 91.9 (b)(2) 14 CFR 91.103 {b) 14 CFR 91.109 14 CFR 91

.119 14 CFR 91

.121 14 CFR 91.151 (a) 14 CFR 91.203 {a)& (b) 14 CFR 91.405 (a) 14 CFR 91

.407 (a) (1) 14 CFR 91

.409 (a) & (b) 14 CFR 91.417 (a)& (b) 14 CFR Title 14 Chapter

1 Sub D Part 60 thru 67

-61.1 to 61.429 The Petitioner wishes tobe granted the exemption for useof the UAS of commercial operations list below.Applications and Operations: Land Surveying and Mapping •Forest Health Monitoring • Harvesting Monitoring •Forest Inventory • Topography •Environmental Assessment •Location of Utilities •Aerial Photography- Real time Forest Inventory Analysis • Mapping Forest Stands and Volumes • Estimating Log and Chip Inventories
on Manufacturing Sites Equipment Inspections •Visual Monitoring
of Equipment The Petitioner believes the useof the UAS's
is moreeconomical and safer tousefor the aforementioned purposes.Use of the UAS rather than amanned aircraft

is moreeconomical
tothe consumer,and beneficial tothe general public due toits small size, low noise and minimal potential for accident. Characteristics

of the Aircraft: The UAS tobe used is the 3DR IRIS+ which has asmall 20 inch wingspan and ultra-light (payload capacity of

.8 pounds) making this platform perfect for precision aerial mapping missions thanks tothe on-board GPS and the related flight management software (Mission Planner) that allows the operator to plan safely and efficiently

amission
in 30, and then monitor

it in real-time

.The onboard cameratakes and collects high definition still images that arelater used to generate mapsand contour lines of the surveyed area. The four main characteristics

of the IRIS+ are

: 1. Very Light Weight The IRIS+ is so light the operator canlaunch
it by hand and let it land onalmost anysurface without requiring

a parachute or landing net

.Its low impact energy (in the caseof acontrolled emergency landing) also significantly reduces the risk of hazardous situations

. 2. Electric-powered The IRIS+
is electric powered.

A brushless engine technology makes
it silent and reliable. 3. Semi-automatic flight The artificial intelligence incorporated within the IRIS+ autopilot system continuously analyzes data from the onboard GPS and takes careof all aspects of the flight under the supervision
of the operator. 4. Option for Manual control Additionally, the IRIS+ provides anoverride capacity that allows the operator totake manual actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspends automated operations and take manual control of the aircraft should
it become necessary
to respond to emergent circumstances

,thanks tothe remote controller provided with the system

. Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations:The Petitioner requests an exemption from the following regulations

aswell as anyadditional regulations that may technically apply tothe operation
of UAS's. 14 CFR 21 H: Airworthiness Certificates Certification Procedures for Products and Parts Reason for Exception It has been determined that similar UAS's do not require anairworthiness certificate
as granted
in Exemption No

.11623, 11650, 11664 and 11734. 14 CFR 45.23 (b): Marking of the Aircraft These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters atleast
3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL"

in letters atleast 2 inches high nearthe entrance tothe cabin, cockpit, or pilot station

. Reason for Exception Even though the UAS will have noairworthiness certificate,
an exemption maybe needed asthe UAS will have not entrance tothe cabin, cockpit or pilot station onwhich the work "EXPERIMENTAL"
canbe placed. Given the size of the UAS, **two~inch**lettering will be impossible. The word "EXPERIMENTAL"
will be placed onthe fuselage
in compliance with 45.29 (f). The FAA has issued the following exemptions
tothis regulation
to Exemptions Nos. 10700, 8738

,10167 and 10167A

. 14 CFR 61.113 (A) 7 (b): Private Pilot Privileges and limitations The regulation provides that no person mayserveasa required pilot flight crewmember

of acivil aircraft of the United States, unless that person: (1) has a pilot certificate or special purposeauthorization issued under this partin that person's physical possession
or readily accessible

.(2) The flight
is only incidental
tothat business or employment.
(3) The aircraft does not carry passengers
or property for compensation

orhire

. Reason for Exception The Petitioner will follow all manufacturers' training programand safety manual.

I also believe these requirements are unnecessaryfor pilot controlled drone flight. Additionally

,currentFAA proposals have omitted this asafuture requirement for small UAS's. 14 CFR 91.7 (a)

:Civil Aircraft Airworthiness Civil Aircraft Airworthiness

: (a) No person may operate

acivil aircraft unless
it is in an airworthy condition

. Reason for Exception It has been determined that similar UAS's do not require anairworthiness certificate, however the petitioner will ensureairworthiness through the combined useof the manufacture's Operations Manual and preflight checks

. 14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the AircraftThis regulation provides that no person may operate anaircraft unless
a current, approved flight manual is in the aircraft. We assumethat the intent of this requirement

is toensurethat flight manual information

is available tothe aircrew while operating the aircraft. We request an exemption
tothis requirement since the aircraft

is not only toosmall to carry documentation;
the documentation would notbe available
tothe crew. Reason for Exception The equivalent level of safety will be maintained
by keeping the flight manual atthe ground control point where the pilot flying the UAS will have immediate accesstoit. The FSS has issued the following exemptions

tothis regulation: Exemption #8607, 8737, 8738, 9299, 9299A tolist afew. 14 CFR 91.103 (b): Preflight Instruction This regulation requires each pilot in commend
totake certain actions before flight toinsure the safety of flight. AS FAA approved rotorcraft flight manuals will notbe provided for the aircraft an exemption will be needed. The petitioner will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 14 CFR 91.109: Flight Instruction The regulation provides that "No person may operate

acivil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." Reason for Exception UAS's and remotely piloted aircraft, by their design sonothave fully functional dual controls. Flight control

is accomplished through the useof acontrol box that communicates with the aircraft via radio communications.
The FAA has approved exemptions for flight training without fully functional dual controls for anumber of aircraft and for flight instruction

in experimental aircraft. See exemption Nos. 5778K
& 9862A

.The equivalent level of safety provided by the fact that neither

a pilot nor passenger will be carried in the aircraft and by the size and speed of the aircraft. 14 CFR 91.119: Minimum Safe Altitudes The regulation provides that over sparsely populated areasthe aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, orstructure. Since the aircraft will be operating
atamaximum
of 400 feet AGL, wecannot comply with this requirement. Reason for Exception The useof UAS will be flown no higher than 400 feet AGL in LOS over developed and developing residential areasthat maybe considered congested areas.That will not always be the casewhen providing

a 'Property Survey' flight because they could be conducted over empty lots or acreageswith nostructures.

In the caseof flying overornear existing private property while providing aerial imagery, property inspections, and property assessments, landowners will be notified
in person by the Petitioner, or by acard left behind by the Petitioner

if requested. The Petitioner will review with the landowners
of associated risks to people and property

.Due tothe small size of the UAS the associated risk to persons, vessels, vehicles and structures

is not comparable
to manned aircraft and shouldbe taken into consideration. 14 CFR 91.121: Altimeter SettingsThis section requires that each person operating anaircraft shall maintain the cruising altitude or flight level of that aircraft, asthe case maybe, by reference toanaltimeter that is set,when operating below 18,000 feet MSL

. Reason for Exception Most UAS do nothave abarometric altimeter.

If does have
aGPS that will calculate altitude

.The Petitioner will limit flights toamaximum altitude of 400 feet AGL as granted
in Exemption No

.11623

, 11664, and 11734

. 14 CFR 90.151 (a) Fuel Requirements
for Flight in VFR Conditions Fuel requirements
for flight in VFR conditions:
(a) No person may begin
a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there
is enough fuel to fly tothe first point of intended landing and, assuming normal cruising speed. (1) During the day, to fly after that for atleast 30 minutes

. Reason for Exception The UAS provides

alow battery warning to indicate when youshould return the UAS tothe launch point. In addition,

a"low" and "critical" battery level warnings and implemented

a"return to Home" (or "Go land") action in these situations. The Petitioner will not initiate

a flight unless (considering wind and forecast weather conditions) there
is enough powerto fly at normal cruising speed tothe intended landing point and all flights will be conducted during daylight hours and attimes nottobe anuisance to others. 14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration This regulation provides
asfollows: •No person may operate

acivil aircraft unless

it has an appropriate and current airworthiness certificate. •No person may operate

acivil aircraft unless the airworthiness certificate required by paragraph (a) of this section ora special flight authorization issued under 19.715 is displayed
atthe cabin or cockpit entrance
sothat it is legible to passengers
or crew

. Reason for Exception To obtain an equivalent level of safety and meetthe intent of 91

.203, documentation
will be housed ata ground control point where the pilot is flying the UAS for immediate accesstothe extent they are applicable
tothe UAS's

.In doing someresearch the FAA has issued numerous exemptions
tothis regulation. 14 CFR 91.405 (a): Maintenance Inspections Each owneror operator of anaircraft- (a) shall have that aircraft inspected
as prescribed

in Subpart

E of this partand shall between required inspections, exceptas provided
in paragraph
(c) of this section, have discrepancies repaired
as prescribed

in part43 of this chapter

. Reason for Exception The Petitioner shall inspect the aircraft prior to every flight. The Petitioner also will follow the manufacturer's recommended preflight checklist and make any repair necessarybefore flights occur. The Petitioner will also maintain

a log of anymaintenance

or repairs performed. 14 CFR 91.407 (a) (1}: MaintenanceOperation after maintenance, preventative maintenance, rebuilding
oralteration

: (a) No person may operate anyaircraft that has under gone maintenance, preventative maintenance, rebuilding,
or alteration unless (1) it has been approved for returntoservice by a personauthorized under 43

.7 of this chapter. Reason for Exception The Petitioner who has the responsibility
for the operation and safety of the UAS will follow the manufactures suggested replacement parts

. 14 FR 91.409 (a)(l) & (2): Inspections Inspections:
(a) Except as provided
in paragraph
(c) of this section, no person may operate anaircraft unless, within the preceding
12 calendar months,

it has had (1) anannual inspection

in accordance with part43 of this chapter and has been approved for returnto service by a personauthorized
by 43

.7 of this chapter

;or (2) An

i nspection for the issuance of anairworthiness certificate

in accordance with part 21 of this chapter

.No inspection performed under paragraph (b) of this section maybe substituted for any inspection required by this paragraph unless
it is performed
by a personauthorized
to perform annual inspect

i onsand is entered asan"annual" inspection

in the required maintenance records

. Reason for Exception The Petitioner will follow manufactu

rer's suggestions
toensurethat the UAS is in acondition for safe flight atall times

. 14 CFR 91

.417 (a) & (b): Maintenance Records Except for work performed

in accordance with 91.411 and 91.413 each registered owneror operator shall keep the following records (l}(i) (ii}(iii) (2)(i)(ii)(iii}(iv)(v)(vi)

for the periods specified
in paragraph (b) of this section

: (1) (2) (3) Reason for Exception The Petitioner will keep
arecord of all repairs and modifications

.The Petitioner also proclaims
touse approved manufactured partsfor all repairs and modifications

. 14CFR Title 14 Chapter

1 Subchapter

0 Parts 60 thru 67- 61.1 to 61.429: Pilot Certification This section pertains to flight rules, pilot certificate requirements, manuals, etc

. Reason for Exception The Petitioner believes that these requirements
are unnecessaryfor pilot controlled drone flights and current FSS proposals have omitted this asafuture requirement for small UAS's

. In Conclusion: I, Jody Rosser, the Petitioner request for exemption from the above mentioned Federal Aviation Regulations

in order to legally operate anUnmanned Aircraft System (UAS)

i nthe National Airspace System
in order to perform the Applicat

i onsand Operations pertaining
to my Forestry work in asafe and controlled env

i ronment. The Petitioner hopes for a timely consideration

as

I have made
aconsiderable investment

in time and finances onthis project. **Since ~~**  Jody Rosser 390 Texas Highway 43 Atlanta

,Texas 75551 903-276-9004 (Cell) thejrosser@gmail.com