Ryan P. Field, Garden Grove, CA. - Section 333 Exemption Petition

November 19th, 2015

Docket Operations, M-30

U.S. Department of Transportation

1200 New Jersey Ave., SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from

14 C.F.R. 61.113(a)&(b); 91.7(a); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1)(2); 91.417(a)(b);

91.119(c).

Dear Sir or Madam:

I, Ryan P. Field, am writing pursuant to the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11

to request an exemption ofthe above referenced FARs to allow operation of a small ultra lightweight

unmanned aircraft system (sUAS) for commercial purposes in the National Airspace System (NAS) regulated by

the FAA.

The purpose of this petition is so I may take my Aerial RC experience and turn into a profitable skill. This would

be accomplished by providing clients with aerial photography and video for the purposes of Capturing Event

Cinematics/Photography, Real Estate Marketing Video/Photography, Structural and Environmental Inspection

through Aerial Video and Photography. All visual media will be taken with the operation of Unmanned Aerial

Systems:

DJI PHANTOM 3 & DJI INSPIRE 1 Series.

This application is substantially based on the FAA's findings in Exemption No. 11351 granted to bizUAS Corp

on April 17, 2015, and in reliance on the analysis provided therein.

I. Contact Information:

Ryan P. Field

9341 Maureen Dr.

Garden Grove, Ca 92841

ryfield12@gmail.com

(714) 333-5249

II. Regulations from which exemption is requested:

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333

b. 14 CFR Part 21, subpart H

c. 14 CFR Part 61.113(a) and {b)

d. 14 CFT Part 91: Relief sought:

i. 91.103{b)(2)

ii. 91.105

iii, 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

Ryan P. Field | Email: ryfield12@gmail | Phone: (714) 333­5249
viii. 91.407

ix. 91.409

x. 91.417

Ill. Extent of Relief and Reason:

The extent of relief I am seeking is the same as in the Granted Exemption No. 11138 for commercial purposes

to include (but not be limited to) videography, cinematography, photogrammetry, industrial inspections and

analyses. I am asking that the FAA grant the amount of relief from each regulation as is deemed appropriate for

the safe operation of the small UAS and inclusion into the NAS.

The reason for the exemption request is because it is currently unlawful to fly UAS's in the NAS for commercial

purposes thereby denying the general public the advantages associated with their use.

This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds including

payload and energy sources:

DJI PHANTOM 3 and DJI Inspire 1. Any other models to be added will be amended to the exemption in the

future.

IV. Benefit to the Public as a Whole:

To obtain Aerial Imagery, using Large Cranes, Scaffolds and Aircrafts were the only methods to do so. They

always possessed high risk of accidents or injury to human life as well as emission damage to the environment

from the use of fuel. UASs pose no such threat since size and lack of combustible fuel alleviates any potential

threat to the public. The costs of operations a UASs compared to the latter also make media captured by UASs

more affordable and to public, which benefits the consumers and the economy.

Congress has already proclaimed that it is in the public's interest to integrate commercially flown UAS's into

the national airspace system, hence the passing of the Reform Act. The lightweight UAS is battery powered and

creates no emissions that can harm the environment. The consequences of an ultra light weight UAS crashing is

far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can

cause catastrophic devastation to the public.

V. Safety not Adversely Affected:

1) Operations will be conducted using only a DJI PHANTOM 3 or a DJI INSPIRE 1 unmanned aircraft.

2) The UA may not be flown at an indicated airspeed exceeding 50 knots.

3) The UA operational altitudes will remain below 400 feet above ground level.

4) The UA must be operated within visual line of sight (VLOS) of the Pilot In Command (PIC). This requires the

PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's

FAA-issued airman medical certificate.

Ryan P. Field | Email: ryfield12@gmail | Phone: (714) 333­5249
5) All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight

(VLOS) of the VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always

maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC must be

designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC

must ensure that the VO can perform the functions prescribed in the operating documents.

6) The operating documents and the grant of exemption must be accessible during UAS operations and made

available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in

the exemption and the procedures outlined in the operating documents, the conditions and limitations herein

take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its

operating documents. The operator may update or revise its operating documents. It is the operator's

responsibility to track such revisions and present updated and revised documents to the Administrator upon

request. The operator must also present updated and revised documents if he petitions for extension or

amendment to the grant of exemption. If the operator determines that any update or revision would affect the

basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant

of exemption.

7) Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection

reveals a condition that affects the safe operation of the UAS, the UAS is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The

Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be

properly documented in the aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement

of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test

flight must make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents must account for all discrepancies, i.e.

inoperable components, items, or equipment, not already covered in the relevant sections of the operating

documents.

10) The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements.

11) The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance

with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft records,

including total flight hours, description of work accomplished, and the signature of the authorized person

returning the UAS to service.

12) Each UAS operated under the exemption must comply with all manufacturer's Safety Bulletins.

13) The authorized person must make an entry in the aircraft record of the corrective action taken against

discrepancies discovered between inspections.

14)UAS operations must be conducted by a PIC possessing at least a private pilot certificate and at least a

current third-class medical certificate. The PIC must also meet the flight review requirements specified in 14

CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

Ryan P. Field | Email: ryfield12@gmail | Phone: (714) 333­5249
15) Prior to operations conducted for the purpose of aerial photography/videography, the PIC must have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior documented

flight experience that was obtained in compliance with applicable regulations may satisfy this requirement.

Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to

accomplish the required flight time. However, said training operations may only be conducted during

dedicated training sessions. During training, proficiency, and experience-building flights the PIC is required to

operate the UA with appropriate distances in accordance with 14 CFR 91.119.

16) Prior to operations conducted for the purpose of aerial photography/videography, the PIC must have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot

operating the make and model of the UAS to be used in operations under the exemption; 5 hours make and

model time may be included in the 10 hours of multi-rotor time prescribed above. The PIC must accomplish 3

take-offs and landings in the preceding 90 days (for currency purposes). Training, proficiency,

experience-building, and take-off and landing currency flights can be conducted under this grant of exemption

to accomplish the required flight time and 90 day currency. However, said training operations may only be

conducted during dedicated training sessions. During training, proficiency, and experience-building flights the

PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 91.119.

17) The operator may not permit the PIC to operate the UAS for the purpose of aerial

photography/videography, unless the PIC has demonstrated and logged in a manner consistent with 14 CFR

61.51(b), the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under

this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

18}UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be

conducted under visual meteorological conditions (VMC}.

19) The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current

FAA-published aeronautical chart.

20) The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or

when visibility is less than 3 statute miles from the PIC.

21) If the UA loses communications or loses its GPS signal, it must return to a predetermined location within

the planned operating area and land or be recovered in accordance with the operating documents.

22) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the

operating documents.

23) The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions)

there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30%

battery power remaining.

24) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization

(COA) prior to conducting any operations under this grant of exemption. This COA will also require the

operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48

hours prior to the operation.

Ryan P. Field | Email: ryfield12@gmail | Phone: (714) 333­5249
25)AII aircraft operated in accordance with this exemption must be identified by serial number, registered in

accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14 CFR part

45, Subpart C. Markings must be as large as practicable.

26) Before conducting operations, the radio frequency spectrum used for operation and control of the UA

must comply with the Federal Communications Commission (FCC) or other appropriate government oversight

agency requirements.

i. DJI PHANTOM 3: 2.400 GHz­2.483 GHz

ii. DJI INSPIRE 1: 5.725~5.825 GHz, 2.400~2.483 GHz

27) The documents required under 14 CFR 91.9 and 91.203 must be available to the PIC at the Ground Control

Station of the UAS any time the UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

28) The UA must remain clear and yield the right of way to all manned aviation operations and activities at all

times.

29) The UAS may not be operated by the PIC from any moving device or vehicle.

30) The UA may not be operated over congested or densely populated areas.

31) Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles,

and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons

remain under such protection. If a situation arises where nonparticipating persons leave such protection and

are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near

vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of operating closer to those objects and

determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, VO, operator

trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a).

32)AII operations shall be conducted over private or controlled-access property with permission from the land

owner/controller or authorized representative. Permission from land owner/controller or authorized

representative will be obtained for each flight to be conducted.

33)Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office

(AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per

instructions contained on the NTSB Web site: www.ntsb.gov. Unless otherwise specified in the grant of

exemption the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR

including, but not limited to, parts45, 47, 61, and 91.

Thank your taking the time to review this Petition. Please advise me of any additional information or changes

needed.

Sincerely,

Ryan P. Field

Ryan P. Field | Email: ryfield12@gmail | Phone: (714) 333­5249

 Ryan Field