### Petition for Exemption Under Section 333 to Allow Commercial Use of Small Unmanned Aircraft Systems ( s UAS)

August 7 , 2015

U.S. Department of Transportation, Docket Operations
We st Building Ground Floor, Room W 12

- 140 1200 New Jersey Ave, S.E. Washington, D C 20590

- 0001

Petitioner: Gregg D. Nole 30699 Longview Lane East Coarsegold, CA 93614
Mobile: 760

- 215

- 5557 gregg.nole@yahoo.com

To FAA 333 Exemptions Manager:

I am submitting my petition for an Exemption under Section 333 for commercial operations of a Small
Unmanned Aircraft S ystem (sUAS) for your consideration. I am an experienced small UAS operator and a FAA
licensed SEL Private Pilot with a current 3 rd class medical and hundreds of fligh t hours.

I am a member of the FAA Wings safety program, AOPA, and I enjoy keeping myself immersed in aviation and keeping my skills current. I regularly attend AOPA and FAA safety meetings, often hosted by FAA official s

. Accordingly, I take the skills and education for safe operation of my personal aircraft (C essna 172P) and s UAS very seriously.

I request a waiver of the sections identified below to operate a s mall UAS for commercial applications including the following: professional marketing, agricult ure/field management, buildings/sites and structural inspections,
real estate marketing including mapping and surveying
, construction, events, and search & res cue (if requested by sanctioned and/or appropriate agencies)

. All these activities will include the collection of still and video images and related data as deemed necessary.

The granting of this exemption would be appropriate due to my professional approach to s UAS operations, my clear understanding of FAA rules and regulations, my awareness of oper ational and restricted airspace, my experience as a pilot, my ongoing FAA approved educational activities, and my attitude of safety first when it comes to any and all flight operations.

I am currently seeking exemption from the following regulations in 14 CFR Part(s):

21, Subpart H 36 61.101 (e) (4) & (5) 61.113 (a) & (b) 91.7 (a) 91.119 (c) 91.121 91.151 (a) 91.405 (a) 91.407 (a)(1) & (2) 91.409 (a) (1) & (2) 91.417 (a) & (b)G. Nole, page 2



### Small UAS Description:

I am request ing exemption for a s UAS weighing less than 55 pounds, (approx. 3lbs.), specifically the DJI Phantom
3 Professional. Th is is a small , 4 electric motor quad

- copter with an on

- board camera, GPS, and other sensors to allow precise flights without the inheren t dangers of larger manned, flammable fuels aircraft.

The craft operates electrically, carries no flammable fuel, has an integrated GPS navigation system providing stabilized flight and ground detection sensors , provides rich location information along with height AGL, speed, distance and direction from operator, battery life, and no

- fly zones. If a loss of remote

- to

- aircraft communication occurs, the s UAS will rise vertically to a safe height before beginning an automatic ret urn

- to

home. The return

- to

- home feature can also be activated manually. Additionally
, it utilizes a compass, blinking

LED position lights, prop guards and other safety features.

The DJI Phantom 3 Professional utilizes a battery powered mobile ground stat ion that connects to a phone or
tablet and displays 720p HD view of everything the camera sees during flight, displayed in real time

. The 4K camera can also be controlled remotely to allow the pilot unobstructed 360 degree views of the flight area.
From takeoff to landing, the sUAS responds immediately to all commands while automatically handling the most complex aspects of safe, stable flight.



### Flight Operations:

I am well versed in conducting safe flight operations and in planning flight paths that mini mize any over

- flight of densely populated or sensitive areas. Flight operations w ill typically be close

- in a nd focused on specific subjects for the applications outlined above. These operations will occur in a very limited area , and of course, I will respect all NAS including no fly zones, TFRs, etc.

My proposed s UAS operations will be conducted at low altitudes below 400 feet AGL, but typically below 200 feet AGL, not over crowds, not near airports and will include myself and a Visual Observer

. If I feel a situation is high risk due to close proximity to people or property, I simply would not accept the mission. Flights will end when battery reserve reaches 2 0 %, and all operations will occur under daytime VFR conditions.

P re

- flight and post

- flight checklists and s UAS examinations
, will detect any abnormalities prior to flight and after
each flight. If the s UAS is unable to satisfy all safety checklists , it will be removed from service until the issue can
be resolved.

Addi tionally, I will follow the DJI Phantom 3 Professional’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements , and I will comply with all manufacturer’s Safety Bulletins.G. Nole, page 3



### Safety Will Not Be Adversely Affected:

Granting this request would not adversely affect safety since operations would be in accordance with all current and/or future sUAS rules and best practices. Safety protocols are listed below:

1. The sUAS will be registered and marked with N333GN.
2. I will c omply with all sUAS maintenance and pre

- flight inspection requirements of the manufacturer. All repair and maintenance work will be conducted or approved by qualified personnel such as those authorized by DJI and will require a test flight after such work . Records of all maintenance and repair
work will be retained on file

. 3. All flight operations will be conducted by two individuals who will maintain verbal communication with
each other at all times and will remain within sight during all flight operations :

a. A Pilot in Command (PIC) who possesses the following credentials:
i. A P rivate P ilot certificate
ii. A current Third C lass medical certificate and/or a valid U.S. driver’s license
iii. A current bi

- annual flight review
b. A Visual Observer (VO).

4. All flight operations w ill comply with the following:

a. The manufacturer ’s Aircraft Flight Manuals and Operation Guides
b. Conducted in VMC c onditions during daylight hours

c. PIC and VO will maintain visual li ne of sight (VLOS) at all times
d. Pre

- flight inspections (including ground con trol station) and safety risk assessments will be conducted prior to each flight

e. Flight altitudes will remain at or be low 400 feet above ground level
f. Flights will n ot take place over densely populated areas or within 5 miles of an airport

g. Any applicable lo cal FSDO requir ements and appropriate FARs
h. All other applicable regulations pertaining to the safe operation of an sUA S

Public Benefit:

The u se of s UAS technology to obtain imagery, information and data

, currently obtained by use of manned flight
or manual methods , will provide significant public benefits :

 Significantly r educes statistical risk to human life and injuries vs. manned aircraft accidents (e.g. power line inspections) and other dangerous acti vities that can be easily avoided (e.g. scaff olding/rigging failures during building or site inspections).

 Greatly r educes the cost of obtaining such information, which benefits businesses, consumers and the
overall economy.

 Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned aircraft and other means currently used to gather required data and imagery.

Aerial videography and photography for marketing and data collection has been around for a long time using
manned fixe d wing aircraft and helicopters, but for many business es , the expense has been cost

- prohibitive andG. Nole, page 4

can create issues in noise sensitive areas . Granting this exemption would expand this service to many more businesses at a much lower cost. Plus, t he s UAS will pose virtually no threat to the public given its small size and
lack of combustible fuel , and it will minimize ecological damage and promote economic growth by providing cost effective and safe operations for all

.
Additionally, I w ill gladly offer my professional services upon request
, and with proper coordination, to any official search and rescue or emergency service s organization to facilitate rescue and recovery operations that
will benefit public safety

.

Suggested Public Federal Register Summary:

“The petitioner is seeking an exemption to operate small unmanned aircraft systems (sUAS) weighing less than 55 pounds to offer cost effective aerial imaging services to businesses including professional marketin g, agriculture/field management, building/site and structural inspections, real estate marketing and surveying, construction, events, and search & rescue activities. Data gathered may include still and moving images captured with onboard camera and GPS co ordinates.”

Section 333 Compliance and Appropriateness:

Based on the size of the aircraft, experience of the pilot, and operational goals, this request appears to be well suited for approval using the criteria outlined in Section 333 of the FAA Moderniza tion and Reform Act of 2012
and will move sa f e flight operations forward in accordance with the intent of Section 333.

I hope to obtain this exemption in order to use my general aviation flight experience to operate sUA S ’s safely
while utiliz ing it for pos itive and productive purposes, within FAA guidelines and regulations. I l ook forward to

your timely response to my request. Please advise if any additional information is needed.

Sincerely,

Gregg D. Nole