U.S. Department of Transportation, Docket Operations

West building ground floor, Room w12

- 140 1200 New Jersey Avenue, SE, Washington, DC 20590 Attn: To whom it may concern Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Northwest Aerial, operator of a Small Unmanned Aerial System (“sUAS”) is equipped to conduct aerial photography and videography, is applying for exemption from the listed (“FARS”) Federal Aviation Regulations. To allow co mmercial operations of it’s (“sUAS”) , as long as such operations are conducted within the guidelines outlined by the FAA. The exemption would allow the operation of Small Unmanned Aerial System (“sUAS”) by a Pilot In Command (“PIC”) accompanied with a Visu al Observer (“VO”) in airspace that is predetermined and limited in a safe and controlled manner. The exemption, if granted would allow Northwest Aerial to conduct commercial operations of (“sUAS”) that meets or exceeds all of the safety requirements congress has set forth in Section 333. Northwest Aerial is a photography service which provides photography and videography services to real estate companies, construction companies, event planners and privet parties: In the scope of imaging services, There is a need to provide services with the use of (“sUAS”) for safety and compliance issues that can only be achieved with (“sUAS”).

-Aerial photography/videography for the purpose of enhancing real estate listings.

-Aerial photography/videography for public and privet events e.g. festivals, parades, weddings, sporting events.

-Aerial photography/videography for construction site inspections and monitoring

-Aerial photography/videography for filmmaking

-Aerial photography/videography for inspection of structures, towers, roof tops

-Aerial photography/videography for the purpose of land use planning and design

-Aerial photography/videography for agricultural inspections and land use planning Northwest Aerial (“The Petitioner”) request exemption from the following (“FARS”) Federal Aviation Regulations. 

# FAR **SUBJECT JUSTIFACATION** 
14 CFR § 45.23 (b) Requirement to display registration number on vehicle Insufficient space on vehicle

14 CFR Part 21 Aircraft certification requirements and procedures Designed for manned aircraft not off the shelf (“sUAS”) small unmanned aerial systems 14 CFR § 61.3 Requirement for pilot certification Part 61 requirements designed for manned aircraft, not sUAS; petition describes training for (“PIC”) pilot in command of sUAS 14 CF R § 91.7 (a) Airworthiness requirement Designed for manned aircraft not (“sUAS”)14 CFR § 91.9 (b) (2) Requirement for manual to be available in the cockpit No cockpit available aircraft is unmanned nobody aboard to read manual. 

# FAR **SUBJECT JUSTIFICATION** 
14 CFR § 91.103 (b) Requirement for crew members to be onboard Unmanned vehicle

.
14 CFR § 91.109 Requirement for dual controls during flight instructions Nobody aboard to operate controls

.
14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation below these altitudes. 14 CFR § 91.121 Altimeter settings Nobody onboard to read altimeter.

14 CFR § 91.151 (a) Fuel requirements Vehicle operates on battery power not fuel. 14 CFR § 91.203 (a) & (b) Requirements for registration and airworthiness certificates to be onboard Unmanned vehicle nobody onboard to read certificates. 14 CFR § 91.205 (b) Aboard cockpit instruments Unmanned vehicle nobody aboard to read instruments 14 CFR § 91.215 ATC transponder and altitu de reporting equipment Unmanned vehicle is to small to carry transponder equipment and also operates below civilian and commercial air traffic safe operating altitudes in the NAS. 14 CFR § 91.401

-91.407 Maintenance, Preventive Maintenance, Alterations and operations after. There is not a standardized maintenance schedule for off the shelf (“sUAS”) Northwest Aerial will perform preflight visual inspections and ensure connectivity to the NAZA GPS flight system. Northwest Aerial will also keep a log book of flights, times, maintenance and any modification’s that can be viewed upon request.(“sUAS”) Are much smaller and safer to operate than conventional helicopters or fixed wing aircraft over

populated areas, crowds, and in close proximity to buildings or events. Northwest aerial is petitioning for exemption to operate it’s DJI Phantom 2 in a comm ercial capacity and operate safely in NAS. Northwest Aerial DJI Phantom 2 is equipped with safety features that enable the user to set altitude limits and limits the radius to which the DJI Phantom 2 can fly from the PIC. It is also equipped with a DJI iOSD (“On Screen Display”) that relays the battery power level of the sUAS and the altitude of the sUAS to the (“PIC”) to a 7” monitor attached to the handheld transmitter . The DJI Phantom 2 is equipped with a safety system so if the battery level of the sUAS falls to 25% the DJI Phantom will return to home and home is a predetermined GPS waypoint that is set before take off. The return to home feature will also be activated automatically if the transmitter ( main controller) loses contact with the onboard receiver of the sUAS. The DJI Ph antom 2 is also fitted with a H3

-3D 3 axis gimbal and a GoPro Hero 3+ camera that will be used to capture video and photographs. Northwest Aerial will only operate it’s sUAS within VLOS of the PIC and VO and will operate at sites with sufficient distance from Heli pads and airports . If the sUAS is operated within 5 miles of an airport or heli pad the operators of the airport will be notified and the PIC will give the right away to any full size aircraft to ensure the safety of the users of the NAS system and public. Flight times will be a maximum of 20 minutes per flight and all flights will be terminated at 25% battery life if that happens before the 20 minute flight time is up. Northwest Aerial will program it’s sUAS to fly at no more than 400 feet AGL and no more than 200 feet above any elevated platform from which any filming is planned. Northwest Aerial will also not fly directly above large crowds at outdoor events but rather capture photos and video from the outer edge of events or from predetermined safe zones within the event that will be blocked off to prevent foot traffic from walking under the airspace of the sUAS. The minimum crew to fly the sUAS will consist of a PIC (pilot in command) and a VO (visual observer) the sUAS operated by Northwest Aerial weighs no more than 5 pounds including payload (i.e. camera, gimbal) and will travel no faster than 30 mph can hover, and can simultaneously move vertically and horizontally. Given the size of Northwest Aerials sUAS and the restricted environment in which we will be operating Northwest Aerial will adhere to the Reform Act’s safety requirements. The sUAS is smaller, lighter and more maneuverable than full sized helicopters and fixed wing aircraft that run on fuel and carry passengers, it operates at lower altitudes and carries no passengers and thereby reduce the risk of serious bodily injury, death and property damage and thereby enhance safety. Low level photography/videography that is done with a sUAS is far more cost effective than chartering a full sized helicopter or fixed wing aircraft and can be completed with no impact on the environment from the use of combustible fuels and far less danger to the safety of the users of the NAS and the public below. Safety and comp liance issues in the construction industry can now be viewed in real time with the DJI P hantom 2 and viewed with the FPV (first person view) monitor. The DJI Phantom operated by Northwest Aerial can also benefit the local agriculture industry by monitoring cropland and inspecting problem areas it can also be a key tool in land use planning for maximum harvest potential. Previous methods would have been to drive through cropland with atv’s, trucks or machinery to get to problem areas resulting in further da mage to the crop. With the use of a sUAS we can help farmers see problem areas and give them a perspective they could never achieve from ground based imagery resulting in more effective treatment of noxious weeds, crop disease, water usage and other agricu ltural related issues.This is the DJI Phantom 2 L.E.D. light indicators upon power up it will flash a sequence of lights to let you

know the status of the sUAS and weather your in GPS flight mode which locks on to several satellites and allows you to set a return to home waypoint. In the event of signal loss or low voltage it automatically goes into RTH mode.In return to home mode you can set the altitude to which the sUAS will ascend or descend to before it

flys to the home waypoint and lands. This is helpful because every area of operation may have different obstacles that the sUAS may have to fly over before it returns to the home waypoint. But if the sUAS encounters an obstacle that it cannot clear in RTH mode you have t he option to manually turn it off and manually control and fly the sUAS back to a safe landing area. This is the picture of the screen when you connect the DJI Phantom 2 to your home PC where you can set all the altitude limits and return to home features and also download new firmware.Here is an example of a screen shot where you can monitor your batteries and their status.

Once the DJI Phantom is plugged into your PC all of your control calibrations can be checked and the UAS can be programed to meet all limitations as far as altitude and return to home features when low voltage or loss of signal occurs.

## Pilot in command qualifications

Northwest Aerial pilot in command Nathan Hueser has extensive history with remote control airplanes, cars, boats and multirotor. I started around the age of 6 when I received my first 2 channel nitro powered remote control airplane built by my father. My father and grandfather were both licensed privet pilots and also licensed sailplane pilots I’ve spent many weekends as a child walking the flight line of Felts Field and Mead and Deer Pa rk airports in the Spokane Wa. Area. I have flown in several types of aircraft including Cessna, Aeronca Champ, Stearm an Biplane and a couple different types of sailplane. As
an adult I still fly R/C aircraft that are much larger and more complicated than the first 2 channel .049 powered one that I started with I’m currently flying a 4 channel Super Decathlon equipped wit h rudder, elevator, ailerons and throttle I’ve also flown a 6 channel airplane equipped with retractable landing gear and flaps. Having flown several types of R/C aircraft over the years in club atmosphere and also teaching others to fly them, and as a former member of the AMA (Academy of Model Aeronautics) I know the importance of safe operation of model airplanes around the public and also understand how important it is to maintain the safety of the NAS. If Northwest Aerial exemption is granted we will
a dhere to the regulations set by congress and the FAA to the fullest extent and conduct business in the safest most professional manner to ensure the safety of the general public and the users of the NAS. Northwest Aerial will also use a VO (visual Observe r) to help ensure the safety of the public and the NAS this person will maintain a visual look out for any potential hazards like overhead power lines, structures, people, Trees, full size aircraft or anything that may pose an issue or safety concern for t he pilot or public on the ground or users of the NAS. Northwest Aerial will always maintain VLOS and never fly behind buildings, trees, walls, clouds or anything that will block the view of the sUAS from the PIC or the VO. Northwest Aerial believes it can provide a very safe very cost effective service to the public without endangering the public or the property in the operational area as a further precaution we will also maintain liability insurance from www.ins uremydrone.net or www.aig.com or www.transportrisk.com or www.drone

-insurance.com whichever can be determined to give the best
coverage suited for the scope of business Northwest Aerial will be conducting. Yours Truly, Nathan Hueser Owner Northwest Aerial 11905 S. Funseth Dr. Spokane Wa. 99223
1

-509

-362

-7056 bignate509@gmail.com