Petition for	333	Exemption

I, Samuel Clayton	Adams,	Commercial	Pilot ( airman	certificate # 3689434) ,	of	8271 Barnett	Dr.	Anchorage, AK	99518	am	petitioning	the Federal	Aviation Administration	(FAA)	for	an	exemption	from part	21,	su bpart	H; and	Sections 45.23(b) ,	91.9(b)(2) ,	91.119,	91.121,	91.151(a),	91.203(a)	and	(b),	91.405(a), 91.407(a)(1),	91.409(a)(2),	and	91.417(a)	and	(b)	of	Title	14,	Code	of	Federal Regulations	(14	CFR).		This	proposed	exemption would	allow	me to	operate	a DJI Inspire	1 Quad	Copter	Unmanned	Aerial	S ystem	(UAS)	for	the	purpose	of	aerial mapping,	videography	and	photography.		The	use	of	a	UAS	for	these	activities	will

have	a	substantial	societal	benefit.		It	will bring	an	over

- head	perspecti ve	to	future

customers that	was	previously only	possible	throu gh	the	prohibitively	expensive use	of	rotorcraft	and	fixed	wing	air craft with	expensive	camera	equipment

. I	would bring this	service	at	an	affordable	price and	due	to	the	simple	nature	of	the	UAS, with	substantial	time	savings.

Due to	the	ever

- improving	nature of	this	technology	a new UAS	can	become	obsolete within	a	few	months	of	release.		Therefore	requiring	a	new	petition	for	exemption	to be	filed	each	time	a	model	of	UAS	not	specified	in	the	original	exemption is	used. In

order to	streamline	this	process	and	to	save	time	and	money	on	both	parties	behalf,

I	am	a lso	seeking	an	exemption	in	addition	the	to	one	listed	above. I	am seeking approval	to	utilize	other	unmanned	aerial	systems (UAS) that	meet	the	operational

limitations	o utlined	in	the	notice	of	proposed	rulemaking	(NPRM)	pertaining	to	the operation	of	s mall unmanned	aircraft	systems in	proposed	part	107	to	Title	14	Code of	Federal	Regulations	(14	CFR)

.

Safety

I	will	utilize	my	knowledge	as	a	professional	pilot	to	main tain	the	highest	level	of safety	durin g	the	proposed	use	of	the	UAS.	F light	would	consist	of	t hree	parts: preflight,	flight and	post	flight.

The	preflight	will	consist	of	exten sive	inspections	of	the area,	the	UAS	and	the airspace in	which	it	will	be	op erating.	A detailed	inspection	of	the	UAS	will	be conducted	and	all	major	systems	will	be examined ,	including	power	plant,	airframe and	controls.		Any	discrepancy	will	be	noted	and	if	the	discrepancy	affects	the	safety of	the	flight,	the	flight	will	not	co mmence.

Operations	will	only	commence	in reasonably	safe	environments	that will	be	strictly controlled	during	the	flight	of	the	UAS.		The	area	will	be	surveyed	for	power	lines, elevated	lights	an d other property	with	the	potential	to	a ffect	the	safety	of the	flight. There	will	be	no	flights	within	the	proximity	of	active	airports	without	first

cont acting	the	appropriate	agencies	or	authorities to	ensure	the	highest	level	of safety	and	compliance	with	all	regulations.		Operations	will	also	not	commencewhe re	there	is	a	reasonable	possibility	of inadvertent physical	contact	with	the populace.

During	the	flight	portion	of	the	operation,	safety	will	be	the	primary	concern.		Given the	size,	weight,	speed	and	limited	operating	area	of	the	UAS;	flight	will	be

in herently	safe.		The	UAS	will	not	be	operated	above	ind ividuals	not	associated	with

it s	operation	and	care	will	be	given	to	avoid	property	that	was	noted	during	the preflight	inspection	of	the	area.

During	the	post

- flight	debrief,	all	individuals	associate d	with	the	operation	will

evaluate the	success	of	the	operation	and	address	any	concerns	brought	forward about	the	safety	of	the	flight.		Any pertinent issues	will	be	noted	and action	will	be taken	to	ensure	the	safety	of	future	flights.

Exemptions	from regulations

All	proposed	exemptions	from	regulations	are	listed	below	and	are	accompanied	by reasoning	as	to	why	it	would	be	unreasonable	to	comply	with	the	regulation.

• 14	CFR § 21	Subpart	H:	Airworthiness	Certificates	and 91.203	(a)	a nd	(b) : Certificati ons	required

o Given	the	size,	weight,	speed,	and	limited	operating	area

associated with	the	aircraft	to	be	utilized ,	an	exemption	is	requested

and would	meet the	requirements	for	an	equivalent	level	of	safety under	14	CFR	part 11	and	Section	333	of	P.L.	112

- 95	(Section	333)

• 14	CFR §	45.23 : Display	of	marks;	general

o An	exemption	is	requested because	the	UAS has	no cabin,	cockpit	or pilot	station	on	which	to	display	certain	words	or	phrases. Furthermore,	is	would	be	unreasonable	to	mark	the	aircraft	with	2 inch	lettering	since	the	airframe	has	dimensions	smaller	than	the minimal	lettering	requirement.		I	will	place the	word	“Experimental”

on	the	airframe	of	the	UAS as	required	by §	45.29(f) so	t hat	a nyone assisting	as	a	spotter and	I will	see	the	markings.

• 14	CFR	§	91.9 (b)	(2) : Civil	aircraft	flight	manual,	marking	and	placard requirements

o An	exemption	is requested from	the	cited	regulations	because	the	UAS

manufacturer	d oes	not	supply	a	flight	manual that	contains information	found	in	manuals	supplied	by	manufacturers	of traditional	aircraft.		Also,	due	to	the	size,	weight,	speed	and	operating

area	of	the	aircraft to	be	utilized	it	would	be	unrealistic	to	expect	it	to.

• 14	CFR §	91.119: Minimum	safe	altitudes

o An	exemption	is requested fr om	the	cited	regulations due	to	the purpose	that	the	UAS being	used	was	created	for.		This UAS is designed for	use in	a n environment	that	is	contrary	to	this	regulation.Als o,	the	UAS	would not	be	operated	at	an	altitude	of	more	than	500 feet	above	the	surface,	as	to	not	interfere	with	any	potential	air	traffic.

• 14	CFR §	91.121 : Altimeter	settings

o An	exemption	is requested because	no	pitot	static	system is installed in	the	aircraft	and	due	to	the	altitudes	is	operates	at,	adherence	to	this regulation	would	be	unrealistic	and	unnecessary.		Also,	GPS	position information	is	transmitted	to	the	aircraft	controller,	providing	mu ch

more	accurate	information	than	what	would	be	shown by	a	traditional

altimeter.

• 14	CFR §	91.151 : Fuel	requirements	for	flight	in	VFR	conditions

o Due	to	the	nature	of	the	aircraft	being	used,	adherence	to	the regulation	would	be	unrealistic.		The	UAS	has an	average flight	time	of approximately	18 minutes	and	a	“return	to	home”	function	in	the event	of	an	impending	power	failure. Therefore,	an	exemption	from the	cited	regulation	is	requested.

• 14	CFR § 91.405(a) : Maintenance	required,	91.407(a)(1) : Operatio n	after maintenance,	preventative	maintenance,	rebuilding	or	alteration,	91.409 (a)(2) : Inspections,	91.417(a)	and	(b) : Maintenance	records

o Exemptions	are requested from	the	cited	maintenance regulations because	they	only	apply to	traditional	aircraft	with an airworthiness

certificate.

Qualifications and	closing

By	g ranting	me	a	section	333	exemption I	will	be	able	to	bring	a	service	to	my community	that	before,	was	asso ciated	with	high	cost and	high	environmental impact .		As	a	professional	pilot,	the	skills	and	knowledge	that	I	have	gained	through training	and	experience	will	add	an	additional	level	of	safety	to	the	operation	of	the UAS.		Coupled	with	an	in

- depth	knowledge	of	airspace,	Federal	Aviation	Regulations (FARs) ,	safety	of	flight	and	science	of	flight	information	I	believe	there	should	be	no question	as	to	the	soundness	of	my	petition	for	exemption.

*Note All	information	regarding	the	Inspire	1	quad	copter	can	be	fo und	on	the manufacturers	webpage	below. Mo del	specifications	will	be	submitted	with	this

document	for	ease	of	reference.

http://www.dji.com/product/inspire

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