Stephen R. Stratton

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U. S. Department of Transportation Docket Management System

1200 New Jersey Ave, SE Washington, DC 20590

January 30, 2016

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of t he Federal Aviation Regulations

Dear Sir or Madam;

In accordance with the Public Guidance for Petitions for Exemption filed under Section 333, I, Stephen R.

Stratton , request exemption from the Federal Aviation Regulations to allow for commercial operations

of one Unmanned Aerial Systems (UAS(s)): a DJI Phantom 3 for purposes of agriculture surveying / crop scouting, aerial photography and videography , and training other operators of a UAS in the National Airspace System (NAS) ; but only so long as such operations are conducted within and under the

c onditions outlined herein or as may be established by the FAA as required by Section 333 or Section 4 9

USC § 44701.

Applicant:

Stephen R. Stratton

1743 E. Avenida de las Flores Thousand Oaks, CA 91362

cptnt stratton@gmail.com

Qualifications:

FAA Certificated Private Pilot

- Certificate No. 3010634

- Airplane Single Engine Land

Attachments:

DJI Phantom 3

1. DJI Phantom 3 Professional User Manual

2 . DJI Phantom 3 Professional Guidelines Disclaimer

3

. Intelligent Flight Battery Safety Guidelines

Regulations from which the exemption is requested:

14 CFR 21, Subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a) 14 CFR 91.7 (a)Stephen R. Stratton

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14 CFR 91.9 (b) (2) 14 CFR 91.103 (b) (2)

14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (l) 14 CFR 91.409 (a) (l) & (a) (2) 14 CFR 91.417 (a) & (b)

14 CFR 21, Subpart H

- In consideration of the size, weight, s peed, and limited operating area associated with the UAS(s) and their operations, I, Stephen R. Stratton request relief from 14 CFR part 21, Subpart H, and any associated noise certification and testing requirements of part 36. The UAS(s) will carry

neithe r pilot, passenger, explosive materials nor flammable liquids.

14 CFR 45.23 (b)

- Even though the UAS(s) will have no airworthiness certificate, an exemption may be needed as the UAS(s) will have no entrance to the cabin, cockpit or pilot station on whic h the word "Experimental" can be placed. Given the size of the UAS(s), two

- inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having th e UAS(s) marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS(s) will see the identification of the UAS(s) as "Experimental."

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)

- Since the UAS(s) will not carry a pilot or passengers I, Stephen R. Stratton request a relief from these regulations. Any pilot in command or (PIC) operating the UAS(s) will hold a Sport Pilot (or greater) certificate. A visual observer or (VO) will be u tilized and required to communicate verbally at all times. The UAS(s) will be limited to operations within visual distance of both the PIC and VO. All UAS operations will take place in a controlled area. The risks associated with the use of a UAS(s) are fa r less than similar commercial aircraft operations.

14 CFR 91.7 (a)

- Since the UAS(s) will not carry a pilot or passengers there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard ex ists for determining airworthiness. Given the size of the aircraft, maintenance, and use of safety checklist prior to each flight, an equivalent level of safety will be provided. All flights will be in accordance with the safety and maintenance recommendat ions found in the DJI Phantom 3 attachments.

14 CFR 91.9 (b) (2)

- Given the size and configuration, the UAS(s) has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An equivalent level of safety will be maintained by keeping the flight manual at the ground station where the UAS pilot will have immediate access to it.

14 CFR 91.103 (b) (2)

- As no FAA approved flight manuals will be provided for the aircraft an exempti on is needed. Alternate procedures including but not limited to reviewing weather conditions, checking flight battery requirements, checking takeoff and landing distances along with those found in theStephen R. Stratton

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attached "Phantom 3 Professional User Manual" will be i mplemented. These actions will provide an equivalent or higher level of safety.

14 CFR 91.109

- UAS(s) and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. An equivalent level of safety will be achieved using the real time ground station data and given the UAS(s) will carry neither a pilot nor passengers.

14 CFR 91.119 (c)

- The UAS(s) will never be operated at a n altitude higher than 400 feet AGL. The UAS(s) will operate in safe areas away from public and traffic and only with permission of the property and structure owners. The UAS(s) will also be restricted by the flight controller to a maximum vertical height of 400 feet AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed of the UAS(s), an equivalent or higher level of safety will be achieved.

14 CFR 91.121

- As the UAS(s) may not have a barometric altimeter, but instead a GPS bar ometric sensor for altitude information an exemption may be required. An equivalent level of safety will be achieved using a ground station which links to a telemetry data link. This will provide the pilot with live flight data monitoring, confirming the a ltitude of the launch site shown on the GPS altitude indicator prior to flight.

14 CFR 91.151 (a)

- The UAS(s) have a limited range and will be limited to operations in a controlled environment. The battery power of the UAS(s) provides approximately 25 m inutes of flight time. The UAS(s) are unable to meet the 30 minute reserve requirement and therefore requires an exemption. An equivalent level of safety will be achieved by monitoring the battery through the ground station and landing with a minimum of 30 percent battery power remaining.

14 CFR 91.203 (a) & (b)

- Given the size and configuration, the UAS(s) have no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An equiv alent level of safety will be maintained by keeping the flight manual at the ground station where the UAS pilot will have immediate access to it. Given the following sections only apply to aircraft with an airworthiness certificate; these sections do not a pply to this applicant. As a safety precaution, the operator will perform preflight inspections and ensure UAS(s) are in working condition before initiating each flight:

14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (l) & (a) (2) 14 CFR 91.417 (a) & (b)

Equivalent Level of Safety

In addition to the safety standards mentioned above the UAS(s) will adhere to the following additional guidelines:

1. The UAS(s) will not be operated within 5 miles of an airport unless prior contact to Air Traffic

Control has been established , and a letter of authorization has been granted

. 2. Flights will not exceed an airspeed of 36 mph (31.3 knots) 3. Flights will be operated at or below an altitude never exceeding 4 00 feet AGL.Stephen R. Stratton

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3. The PIC and VO will communicate verbally at all times.

4. UAS operations will not be conducted during night.

5. All operations will be conducted under visual meteorological conditions.

6. The UAS(s) will land with a minimum 30 percent battery reser ve remaining.

7. The UAS(s) will only be piloted within visual line of sight.

8. The UAS(s) will utilize an internal flight safety feature that will return to a pre

- programmed position and land if communication with the remote control is lost.

9. Preflight inspe ctions and protocol will be followed prior to all operations.

10. The UAS(s) will abort flight in the event of unpredictable obstacles or emergencies.

Public Interest

I, Stephen R. Stratton , believe the use of a UAS in lieu of a manned aircraft would enha nce safety and reduce the environmental impact compared to similar operations conducted with a manned aircraft carrying a crew and flammable fuel. As a professional aviator I experience the need to keep our skies safe. My primary role with UAS operations w ill be agriculture crop scouting, aerial imagery and videography. I will also assume the role to educate and train existing and future operators with their UAS in the NAS. These operators will no doubt be flying UAS with cameras and such the need to educat e them as to their operation while maintaining the privacy of their neighbors. I, Stephen R. Stratton, would gladly offer my services upon request and with proper coordination to any official search and rescue or emergency services organization to benefit the public.

Privacy

All flights will occur over private or controlled areas with the owner's consent. Capturing people in images will rarely occur. If a person is captured in a collected image they will have consented prior to filming or otherwise have agreed to be in the area prior to the filming taking place.

Sincerely,

Stephen R. Stratton