U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w 12-140 1200 NewJersey Avenue, S.E. d I' ·, .·i

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### Petition for Exemption Under 14CFR 11.81 to Allow Commercial Use of Unmanned Aircraft System

October 23, 2015

Petitioner: Steven Michael Rupp 1150 Darlene Lane #332 Eugene, OR 97401 541-731-2171 Email: flywithsteve@gmail.com Greetings, ...**l.~**

This application is.substantiallybased on the FAA's findings in Exemption No. 11062 granted to Astraeus Aerial on September 25, 2014, and in**.relian~;:~** on the analysis provided therein. 1. Sections from which exemptions are sought: Application is hereby m,ade for exemption from:

. , a. FAA Modernization an<;J Reform Act of2012, PL112-95 F,EB. 14, 2012, Section 333 b. 14 CFR Part 21, subpart H c

..14 CFR Part 61.113(a) and (b) d. 14 CFR Part 91: i.. 91.103(b)(2} ii. 91.105 iii. 91.109 iv. 91.119 v. 91.121 vi. 91.151 vii.**91.40~** viii.**~1.407** '. ix. 91.409···· X•. '91.417 Relief sought: a. I, Steven M. Rupp wish to operate Unmanned Aircraft Systems for commercial purposes to include, (but notlimited to); land survey!ng,**photogramm~try,videography,** photography, inspections and analyses. This relief is sought because commercial use of .UAS are currently prohibited by law unJess performed under an exemption. b. This exemption will cover any a,irframe thatweighs less than 55 pounds, including payload and energy sources:

. _ . ... , .· i. MULTIROTOR service-drone G4 modelsii. DJI Phantom and Inspire models iii. Altavian Nova models iv. Other models to be added by future amendmenttothis exemption. c. Iwish to contract commercial services as an independent contractor and a qualified pilot, to operate UAS within limits ofexemption 333. Public benefit: a. UAS technologyto obtain imagery, information and data currently obtained by use of manned flight or manual methods: i. Reduces statistical risk to human life due to manned aircraft accidents, (e.g., powerline inspections) and due to other dangerous activities that can be avoided, (e.g., scaffolding/riggingfailures duringstack or bridge inspections). ii. Reduces the cost ofobtaining such information,which benefits consumers and the economy. iii. Reduces environmental impact by eliminating sources ofhydrocarbon emissions from manned aircraft. iv. Allows for companies to contract ratherthan havingto employ aspecific person within their company to perform work. Safety not adversely affected: a. I will only operate aircraft registered and marked in accordance with Section 44711 and Part 47 and part 45, subpart 

### C. Itwill be my responsibilityto ensure this before service is rendered as the pilot in command. b. Aircraft will comply with maintenance and inspection requirements ofthe manufacturer. All repair and maintenance workwill be conducted orapproved by qualified personnel. Records ofall maintenance and repair work will be kept in a maintenance log for each aircraft. c. Operations will be conducted by Steven M. Rupp whom will maintain visual capability at all time duringflight. i. I, Steven M. Rupp, Pilot In Command, possess the following credentials: 1. An Airman Certificate issued under 14CFR 61 (At least an Airline Transport Certificate) screened byTSA. 2. A Second Class medical certificate issued under 14 CFR 67. 3. A Bi-annual flight review under 14 CFR 61.56 4. A completion ofa course ofinstruction in safe UAS flying conducted by Unmanned Experts Inc. (or equivalent instruction). 5. At least 200 cycles and 25 hours offlight experience in a UAS rotorcraft (or UAS fixed-wing in the case offixed-wing flight operations underthis exemption). Such cycles and hours may be gained duringflights underthis exemption ifasafe distance is maintained from persons in accordance with 14CFR 91.119. 6. At least 5 hours offlight experience and 3 takeoffs and landings in make and model beingflown in the prior90 days. Such cycles and hours may be gained during flights underthis exemption ifasafe distance is maintained from persons in accordance with 14 CFR 91.119.

### d. All flight operations will be conducted in accordance with valid Certificates of Authorization. e. All flight operations will comply with the following: 

### i. The manufactures' Aircraft Flight Manuals and operation guidelines ii. Operations polices including lost communication and otheremergency and safety procedures. 

### iii. Conducted in VMC conditions during daylight hours iv. PIC will maintain VLOS at all times. v. Pre-flight inspections (including ground control station, ifany} and safety risk assessments will be conducted priorto each flight. vi. Flight altitudes will remain below400 AGL vii. Flight ground speeds will not exceed 50 knots. viii. Not intrude intoCiass B, C, or Dairspace1 

### or published approach, SID orSTAR, or

· take place within 5 miles ofan airport unless priorapproval is issued bythe

respective controlling agency and a NOTAM has been issued. ix. Not be made near persons as required in CFR 91.119 and notover persons on the ground withouttheir prior permission. x. Each flight will be logged in PIC's logbook and the aircraft logbook xi. Not exceed 75% ofthe batteryorfuel capacity ofthe aircraft, or 30 minutes, whichever occurs first. xii. Any incidents will be reported within 24 hours ofoccurrence. xiii. Steven Rupp will maintain liability insurance ofat least 1,000,000. xiv. Any applicable local FSDO requirements. xv. All other applicable regulations concerned with the operation ofaircraft.
Please advise me ofany additional information or changes that are required. Sincerely,
Steven Michael Rupp Certificate#3127531 CFI/CFII/MEI/ATP 

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