Nic Summers 212 S. Albert St. Mount. Prospect, IL 60056

May 11, 2015 Hon. Michael Huerta Administrator Federal Aviation Administration U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 May 2 0, 2015 Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from certain parts of the FARs. Dear Administrator Huerta: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ( the Reform Act) and 14 C.F.R. Part 11, Nic Summers, a professional FAA certificatedAirman holding a Aircraft Dispatcher and Private Pilot rating, in addition to working as

a freelance professional photographer for the Chicago Tribune Media Group, hereby a pplies for a summary exemption from the listed Federal Aviation Regulations (“FARs”) to allow him to operate small Unmanned Aircraft Systems (“sUASs”) under the conditions and limitations set forth in this Petition. The requested exemption would permit th e operation of small, unmanned and relatively inexpensive sUASs under controlled conditions in airspace that is (1) limited, (2) predetermined, (3) news gathering which would provide safer and less costly alternatives to the already safe news gathering ope rations presently using manned helicopters and airplanes, (4) aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities, (5) aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation. Approval of this exemption would thereby enh ance safety and fulfill the FAA Administrator’s responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. The name and address of the applicant is: Nic Summers 212 S. Albert St. Mount Prospect, IL 60056 Telephone: (847)284 - 2777 Email: nic.summers @jetphotos.com Regulations from which the exemption is requested as follows:14 CFR Part 21

14 CFR § 61.3 1 4 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2) 14 C.F.R. § 91.103 14 C.F.R. § 91.109 14 C.F. R.§ 91.119 14 C.F.R. § 91.121 14 CFR § 91.151 (a) 14 CFR § 91.203 (a) & (b) 14 CFR § 91.205(b) 14 CFR § 91.215 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2)14 CFR § 417 (a) & (b)

List examples of previously granted exemptions similar to his operation. AERIAL PRODUCTION SERVICES, INC. Regulatory Docket No. FAA –2014 –0836 Mr. Michael Fortin, CineDrones, LLC Regulatory Docket No. FAA - 2014 - 0798 Mr. Adam C. Orens Regulatory Docket No. FAA - 2014 - 0939 Mr. Henry H. Perritt, Jr. Regulatory Docket No. FAA- 2014 - 0608 Ms. Melinda Sokoloski Regulatory Docket No. FAA- 2015 - 0004 Mr. David L. Farley Regulatory Docket No. FAA –2014 - 11 10 Mr. David Ho Regulatory Docket No. FAA –2015 –0114 Mr. Gregory Zonsius Regulatory Docket No. FAA - 2015 - 0056 Mr. Seth Hellinga Regulatory Docket No. FAA –2015 –052Mr.Wesley W. Myers, Jr.

Regulatory Docket No. FAA –2015 –0443 Mr. George Riet hof Regulatory Docket No. FAA- 2015 - 0390 Mr. Darrell Reid Wilson Regulatory Docket No. FAA –2015 –0378 Ms. Terry L. Carbonell Regulatory Docket No. FAA- 2015– 0417

The Appendix describes the FARs from which an exemption is requested and summarizes t he justification for each requested exemption. The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the Reform Act, which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may o perate safely in the national airspace system (NAS) before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Administrator must determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS withi n visual line of sight of the operator. Reform Act § 333 (a).If the Administrator determines that such vehicles “may operate safely in the national

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in t he national airspace system.” Id. § 333(c) (emphasis added). The Secretary has delegated his aviation authority to the Administrator of the FAA. The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory req uirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702 - 44716 of th e Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC§ 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1). The petitioner is a professional FAA certified Airman Flight Dispatcher and is cu rrently employed with United Airlines and has been for the last 21 years in this position. He also holds an FAA certified Private Pilot license. The Petitioner has spent over 200+ hours, on a countless number of flights, observing ALPA represented pilots on the flight deck of 14 CFR FAA §121 turbojets and in discussion with the flight crew of these flights as required by 14 CFR FAA §121.463 in the performance of his Airman duties. In his position as a Flight Dispatcher, he is responsible for the safe op eration of every flight that he dispatches, along with the Captain of each flight. He daily plans international flights around the globe. He must brief Captains of all known issues that will affect the safety of flight. He, as a Flight Dispatcher , is ke enly aware of all aspects of safe flight. The petitioner, on a daily basis must check, including, but not limited to, space weather/solar events that might affect navigation and communication reliability for the Boeing 747, B777, B787 and other fleet type s operated by United Airlines, andplan accordingly. Solar storms have the ability to reduce GPS signal quality thus

affecting the ability to operate a UASs safely. As an example of the situational awareness he maintains in his aviation work, he has know ledge of many dynamic situations on a global basis affecting the safe operation of his flights. There is extensive global volcano activity to consider for ash avoidance, political even t s, NOTAMS for all stations, constant review of weather not only for or igin and destination station but also for all enroute ETOPS airports and maintains operational control for all his flights as required by 14 CFR FAA §121.535 and performs all additional duties under 4 CFR FAA §121.591. He, as a flight dispatcher must atten d 18 hours of recurrent Flight Dispatch training annually in addition to a minimum of 5 hours riding as an observer on the flight deck of the various types of aircraft and global regions he dispatches under 14 CFR FAA § 121.463. The Petitioner is subjected to random drug and alcohol tests account of his safety sensitive position as a professional FAR part 121 Flight Dispatcher at United Airlines. The petitioner is also a professional freelance photojournalist for the Chicago Tribune and formerly the Chicag o Sun - Times, photographing sports and news events. His regular weekly assignments involve various news worthy and sports events happening on a daily basis covering current and breaking events as assigned by his photo editor at the Chicago Tribune Media Group and Pioneer Press. He has photographed newsworthy events at O'Hare published in the Chicago Tribune and was the only photographer present at times. He has photographed hundreds of airplanes departing and arriving O'Hare and other airports over the ye ars and has sold thousands of dollars ’ worth of photos to United's ALPA represented pilots and to ALPA directly since 2000. The wide availability of small Unmanned Aircraft Systems, also known as

“ microdrones,”capable of carrying high - quality professio nal cameras and priced at affordable levels intrigued the petitioner. His entire professional career has involvedexploring new technologies and adapting them to capture good imagery to inform the

public. In May 2015, he bought a DJI S1000+ Spreading Wings , installed a three axis gimbal and a Canon 5DIII and has flown them for total of 30 hours over remote areas of the Chicago metropolitan area and suburbs northwest of Chicago outside of controlled airspace for recreational purposes, exploring the potential and the limitations of its photo/video subsystem and the UASs aircraft. The Petitioner has also a second sUASs DJI Phantom 3 Professional used to practice flying manually and help maintain proficiency in flying. He is pleased with the quality of the i magery captured and has edited it into a number of photographic vignettes that meet his high standards for technical quality and artistic merit. Now, a number of people, some professional colleagues and some strangers , have heard about Petitioner ’ s activ ities and have seen the results and are pressing Petitioner to undertake additional microdrone photography for compensation. Many competitors of Petitioner are actively flying sUAS to conduct aerial photography for commercial purposes, notwithstanding th e FAA’s stated prohibition. He also notes and has read the congressional mandate in sections 332 and 333 of the FAA Revitalization and Reform Act of 2012 that the FAA move quickly to accommodate the economic and societal benefits that can result from wides pread deployment of sUAS technology. Accordingly, Petitioner applies for authorization under the Federal Aviation Act, and the FARs rules to undertake the following activities for commercial purposes. Unless the Petition is granted, Petitioner will be at a significant competitive advantage if he, as he prefers, complies with FAA policy. Vehicle The Petitioner will fly an 8 engine DJI S1000+ Spreading Wings octocopter equippedwith a three - axis gimbal and Lumix camera with plans to interchange other simi lar

digital cameras as the needs arise. This vehicle has built in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator, and to exclude it from class B, C, and D airspace. The S1000+ will utilize a DJI A2 flight controller with GPS receiver to maintain autonomous position and operational control at all times. The S1000+ A2 flight controller has a programmed fail - safe capability to autonomously climb or descend but not over 400' AGL an d then return to the launching point if the wireless control link is interrupted or if the operator attempts to exceed any of the height, radius, or airspace limitations programmed into it. The vehicle weighs about 11 pounds empty and has a maximum gross w eight of approximately 24 pounds. It has a top speed of about 50 knots. It has 8 - eight fixed - pitch 15 inch rotors, thrust from which is varied by changing RPM. It is powered by multiple lithium polymer batteries for redundancy and safety. Also the Peti tioner, will also operate a DJI Phantom 3 Professional when conditions exist based on the Petitioner ’ s evaluation of the most safe and efficient equipment to complete the job. The Phantom 3 weighs less than 5 pounds, far less than the 55 pound limit incl uding camera and gimbal. Aircraft specifics are appended below. 

### Flight profiles

• He will, prior to every operation, complete an extensive pre - flight check list specifically customized by the manufacture for this type of sUAS to assure that its compass an d GPS system are properly calibrated and that the return - to home feature, altitude, and radius limitations work. If any parameters of operation are not met, he will ground the aircraft until he is assured it will operate in complete compliance with Sectio n 333 and the manufacturers limitations.• He will operate it on aerial photography/video missions only during daylight

hours.

• He will at all times operate the UASs (S1000+ and Phantom 3 Professional) with safety and in compliance with the limitations o f the exemption at all times.

• He will not operate it in controlled airspace. In the unlikely event that a manned aircraft flies below 400 feet AGL where the petitioner i s operating his S1000+, he will keep both the vehicle and manned aircraft in sight a nd avoid the manned aircraft.

• The petitioner will program his UASs so they will not fly above 400 feet AGL at any time and will maintain visual line of sight(VLOS) at all times.

• The UASs will remain within 2600' horizontally or within the limits of visu al line of sight (VSOL). At no time will the UASs be out of VLOS.

• The UASs are equipped with anti - collision LED lights to allow for higher visibility and greater observability of the vehicle.

• He will maintain his Private Pilot currency and review all pertinent FAA documents and regulations necessary to operate the S1000+ and Phantom 3 Professional safely.

• He will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft co mponents.

• Flight will be terminated to land at home with a minimum of 25 percent battery reserve.• Flight will be operated within line of sight of the Pilot in Command(PIC) and/or

Visual Observer (VO) The Petitioner's proposed operations satisfy the cr iteria provided in Section 333 of the Reform Act relating to size, weight, speed, operating capabilities, proximity to airports and populated areas, operating within visual line of sight , and respect for national security. The Petition justifies grant of t his requested summary exemption to allow the Petitioner to obtain aerial photography and video with his microdrone s . This Petition is similar to the case presented by exemptions granted and previously cited.


### DJI S1000+ Spreading Wings Manufacture r SpecsFrame Diagonal Wheelbase 1045mm Frame Arm Length 386mm Frame Arm Weight

(Including Motor, ESC, Propeller ) 325g Center Frame Diameter 337mm Center Frame Weight (with Landing Gear Mounting Base,

Servos) 1520g Landing Gear Size 460mm(Length)×511mm(Width) ×305mm(Height)

Motor Stator Size 41×14mm KV 400rpm/V Max Power 500WWeight(with Cooling Fan) 158g

ESC Working Current 40A Working Voltage 6S LiPo Signal Frequency 30Hz ~ 450Hz Drive PWM Frequency 8KHz

Weight(with Radiators) 35g

Foldable Propeller (1552 /1552R) Material High strength performance engineered plastics Size 15×5.2inch Weight 13g Flight Parameters Takeoff Weight6.0Kg ~ 11.0Kg Total Weight 4.4Kg Power Battery LiPo (6S,10000mAh~20000mAh,15C(Min)) Max Power Consumption 4000W Hover Power Consump tion 1500W (@9.5Kg Takeoff Weight) Hover Time 15min (@15000mAh & 9.5Kg Takeoff Weight) Working Environment Temperature

- 10 °C ~ +40 °C

### DJI Phantom 3 Professional Manufacturer SpecsAircraft Weight (including battery and propellers)

1280 g Diago nal size (including propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Hover Accuracy

• Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m

• Horizontal: +/- 1.5 m Max Speed 16 m/s (ATTI mode, no wind) Max Altitude Above Sea L evel 6000 m Operating Temperature 0°C to 40°C GPS Mode GPS/GLONASSAppendix FAR section Subject Justification

14 CFR § 45.23(b) Requirement to display registration number on vehicle Insufficient space on vehicle
14 CFR Part 21 Aircraft cert ification requirements and procedures Designed for manned aircraft; not suitable for offthe - shelf sUAS 14 CFR § 61.3 Requirement for pilot certificate Part 61 requirements designed for manned aircraft, not sUAS; petition describes training for sUAS o perator 14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; not suitable for off the - shelf sUAS 14 CFR § 91.9 (b) (2) Requirement for manual to be available in the cockpit No one aboard to read manual 14 CFR § 91.103(b) Req uirement for crew members to be onboard Unmanned vehicle 14 CFR § 91.109 Requirement for dual controls during flight instruction No one aboard to operate controls 14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation below th ese altitudes 14 CFR § 91.121 Altimeter settings 14 CFR § 91.151(a) Fuel requirements 14 CFR § 91.203 (a) & (b) Requirement for registration and airworthiness certificates to be onboard 14 CFR § 91.205(b) Cockpit instruments



### Appendix FAR section Subject Justification 14 CFR Part 21 Aircraft certification requirements and procedures Designed for manned aircraft; not suit able for off- the - shelf sUAS 14 CFR § 61.3 Requirement for pilot certificate Part 61 requirements designedfor manned aircraft, not sUAS; petition describes training for sUAS operator 14 CFR § 91.7 (a) Airworthiness requirement Designed for ma nned aircraft; not suitable for off- the - shelf sUAS 14 CFR § 91.9 (b) (2) Requirement for manual to be available in the cockpit No one aboard to read manual 14 CFR § 91.103(b) Requirement for crew members to be onboard Unmanned vehicle 14 CFR § 91.109 Requirement for dual controls during flight instruction No one 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 No one aboard to read altimeter 14 CFR § 91.151(a) Requirement for registration and airworthiness certificates to be onboard No one aboard to read certificates 14 CFR § 91.205(b) Cockpit instruments requirement No one aboard to read instruments 14 CFR § 91.2 15 Transponder requirement Vehicle has insufficient usefulload; will be operated below ATC radar coverage 14 CFR § 91.405 (a) Inspection requirements Designed for manned aircraft; not suitable for off- the - shelf sUAS 14 CFR § 91.407(a) (1) Ins pection approval requirements Designed for manned aircraft; not suitable for off- the - shelf sUAS 14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft; not suitable for off- the - shelf sUAS 14 CFR § 91.417 (a) & (b) Mainten ance records requirements Designed for manned aircraft; not suitable for off- the - shelf sUAS