1

Michael K. Martin

7086 Greenleaf Avenue Parma Heights, Ohio 44130

Date: December 21, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. Washington, DC. 20590

RE: Petition of Michael K. Martin for Exemption Pursu ant to Section 333 of the FAA Reform

Act Attn: To whom it may concern

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14C.F.R. Part 11 Michael K. Martin, operator of a Unmanned Aircraft System (UAS) equipment to conduct aerial photography and videograp hy as a service to private yacht owners for the purpose of listing their yachts for sale or pr oviding personal videos of their yachts, hereby applies for an exemption from the listed Feder al Aviation Regulations (FARs) to allow commercial operation of my UAS, so long as such operati ons are conducted within and under the conditions outlined herein or as may be establishe d by the FAA as required by Section

333.1.

As described more fully below, the requested exemption would permit the operation of a UAS under controlled conditions in airspace that is 1) limite d 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Micha el K. Martin to conduct commercial operations of unmanned aircraft systems (UAS) meeting o r exceeding all of the operational and safety requirements Congress has set forth in Sectio n 333, Page 2.

I, Michael K. Martin, am a Licensed Yacht Broker and an FAA licensed Private Pilot with experience in fixed wing aircraft. I am also an experi enced RC pilot with a back ground in fixed wing and multi-rotor RC aircraft operations. I plan to use my skills as a pilot and operator of an Unmanned Aerial System to offer services including:

• Photography and Videography of Yachts underway, doc ked or in storage on land

• Providing existing clients and perspective clients with personal videos of their yachts

I am not compensated for providing these services but be lieve that the photography and videos produced for the purpose of listing a yacht does lead t o a higher rate of interest in my listings.

Statutory Authority Section 333 Titled “Special Rules for Certain Unmanned Aerial Systems”, provides a mechanism for seeking expedited FAA authori zation of safe civil UAS operation in the NAS. Section 333(a) states that the FAA “shall det ermine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by Sectio n 332(b)(1) of this Act or the guidance required by Section 334 of this Act.” In Section 332(b )(1) Congress made it clear that Section 333 provides a mechanism for “expedited operation aut horization” if several factors are met. Petitioner meets all requirements to permit FAA appro val of commercial UAS operations:2

The Petitioner Requests Relief From the Following: Regulations from which the exemption is requested:

14 CFR Part 21 14 CFR 45.23(b)

14 CFR 45.29 14 CFR 61.113(a) and (b)

14 CFR 61.133 14 CFR 91.7(a)

14 CFR 91.9

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 14 CFR 91.203(a) & (b) 14 CFR (91.401 – 91.417)

Unmanned Aircraft Systems UAS are often seen as superior to the use of helicopters due to the fact that they are smaller, less costly equipment, lo wer noise impact and that they promote a higher degree of public safety than large manned a ircraft.

I am petitioning for exemption to enable myself to o perate a DJI Phantom 2 Vision Plus and DJI Phantom 3 Advanced, both equipped with High Definiti on camera. The subject UAS has onboard capability to limit the operating height above ground, and to limit the radius of operation from the operator. These DJI Phantoms have a failsafe a utopilot system. If the link between the ground control transmitter and the UAS is broken, the UAS will enter a SAFE Mode and automatically go into stable flight and return to th e location from which it was launched or return to the operators location depending on the mode selecte d. The control transmitter also incorporates a function that allows the operator to act ivate a Return to Home feature that automatically returns the UAS to the launch location a nd lands safely at the point of launch or return to the operators location depending on the mod e selected.

While flying for commercial purpose I would fly no hi gher than the maximum allowed altitude of 400 feet AGL (typically no higher than 100 feet A GL) and in full visual line of site and only under VFR, Daylight conditions. I would not be operat ing the UAS near persons on the ground, sporting events or large gatherings of people, utilities or other hazards to persons or
property.

Aircraft

The Petitioner operates the DJI Phantom 2 Vision Plus and DJI Phantom 3 Advanced UAS’s manufactured by DJI in Shenzhen, China. These Phantom s main rotor diameter is 23.2 in and has a gross flying weight of 2.8 lbs. What makes these DJI Phantoms such a great camera platform is the advanced technology and safety feature s integrated into the flight systems that provides for incredible ease of use and stability. Pilo ts can control these DJI Phantoms movements in many directions – including pitch (forward and backward), roll (left and right), elevator (up and down), and yaw (turn left or right ). The built-in GPS system aids in stabilizing the aircraft and will automatically return it back to its home position if communication between the remote control and quad copter are lost. These DJI Phantoms are controlled with the included proprietary full-range transmitter.3

These DJI Phantoms have flight modes that have been sp ecially programmed for capturing aerial video and images. Both feature self-leveling a nd use GPS and altitude sensors to precisely hold position in a hover.

The Return Home function will automatically land at t he home position or the operators location depending on the mode selected. This feature can be act ivated at any time with the flip of a switch. When activated, these DJI Phantoms will automati cally climb to a designated safe altitude and fly itself back to the place its motors w ere first started or the location of the operator depending on the mode selected and land without any h elp from the pilot.

As an added safety feature, these DJI Phantoms operates within geo-referenced flight boundaries which I have configured to below 400 feet A GL and 1,500 feet horizontally. An intuitive PC programming interface makes monitoring systems, adjusting settings and calibrating sensors as easy as point and click.

The Inertial Measurement Unit (“IMU”) has a built-in inertial sensor and a barometric altimeter

that measures both attitude and altitude. The inerti al measurement tells these DJI Phantoms how it’s tilted, and the gyros tell it if it’s rotatin g in any particular direction.

These DJI Phantoms compasses read geomagnetic information and assists the GPS to accurately calculate the position and height of the airc raft.

These DJI Phantoms have LED flight indicators beneath each of its four rotor arms and in

the rear. The LEDs illuminate to indicate the status o f the flight control system and alert the PIC of any possible issues.

A Pre-flight inspection will be performed by the PIC in accordance with the factory instruction manual. Propellers will be inspected prior to each flig ht and replaced with manufacturer authorized replacements if damage such as cracks, nicks o r blade deformation are found.

Maintenance will be in accordance with the manufacturers instruction manual and all manufacturer service bulletins. Only manufacturer auth orized parts will be used as replacements.

FCC Information

The DJI proprietary transmitter used for controlling t hese DJI Phantoms complies with part 15 of the FCC rules. Operation is subject to the following tw o conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. The DJI proprietary transmitter used for the control o f the UAS is wireless technology which has been tested and found to be compliant with applica ble regulations governing a radio transmitter in the 2.400GHz to 2.4835 GHz frequency range.

Antenna Separation Distance

When operating the DJI proprietary transmitter, the PIC will maintain a separation distance of at least 5 cm between his body (excluding fingers, hands, w rists, ankles and feet) and the antenna to meet RF exposure safety requirements as determined by FCC regulations.4

Equivalent Level of Safety

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system

in the world and to minimize the risk to the NAS or to persons and property on the ground, the Petitioner agrees to be bound by the following limit ations and conditions when conducting commercial operations under an FAA issued exemption:

1. For the purpose on ensuring the UAS will be operat ed in a safe and professional way:

a. The UAS will not be flown:

• In a careless or reckless manner.

• At a location where UAS operations are prohibited.

2. UAS PIC will:

a. Yield the right of way to all manned aircraft.

b. See and avoid all aircraft with the assistance of an observer if needed.

c. Not fly at an altitude greater than 400 feet AGL or within 5 miles of an airport without notifying the airport operator.

d. Not interfere with operations and traffic pattern s at any airport, heliport or seaplane base.

e. Not exceed a takeoff weight of 55 pounds (Including payload)

f. Ensure that the aircraft is identified by affixin g the aircraft registration N

Number on the outside of the UAS.

g. Not operate the UAS under the influence of alcohol or while using any medications that could adversely affect the PICs ability to safely control

the aircraft.

h. Not operate the UAS carrying pyrotechnic devices tha t explode or burn, or any device which propels a projectile or drops any object that creates a hazard to persons or property.

3. The UAS will not be flown unless:

a. The aircraft, control system and pilot skills have su ccessfully demonstrated all maneuvers intended or anticipated pri or to the specific

event.

b. An inexperienced pilot is assisted by an experienced p ilot.

4. All pilots shall avoid flying directly over unprote cted people, vessels, vehicles or structures and shall avoid endangerment of life and pr operty of others.5 5. A successful radio equipment ground-range check in accor dance with manufacturer’s recommendations will be completed before the first flight of a new or repaired model aircraft.

6. The UAS must use the radio-control frequencies curren tly allowed by the Federal Communications Commission (FCC).

7. The UAS will not knowingly operate within three (3) miles of any pre-existing flying site without a frequency-management agreement.

8. Excluding takeoff and landing, no UAS may be flow n outdoors closer than 25 feet to any individual, except for the PIC and the ob server located at the takeoff

site.

9. Under no circumstances may a pilot or other person to uch a UAS in flight while it is under power, except to divert it from striking an individual.

10. The PIC of the UAS shall:

a. Maintain control during the entire flight, mainta ining visual contact without enhancement other than by corrective lenses prescribed f or the pilot.

b. Always fly with the assistance of a ground based observ er if needed.

General Operating Standards

In addition to the above rules, the petitioner agree s to be bound by the following limitations and

conditions:

• Michael K. Martin will operate the UAS in line of s ite of a pilot and/or an observer and will operate at sites that are a “sufficient distance” f rom populated areas. Such operations will insure that the UAS will “not create a hazard to users of the National Airspace System or the public.

• Before operation of the UAS within 5NM of an airpo rt with a control tower, the control tower will be notified to gain permission to operate the UAS. The PIC will give the position, altitude and times of operation. The UAS wi ll not be operated at an altitude of

over 150 feel AGL. Weather minimums will be 3 miles visibility and 1000 foot ceiling.

Before an operation within 5NM of a non-tower contro lled airport, airport operations will be notified and the PIC will give right of way to a void flying in the proximity of full scale manned aircraft. At no time will the UAS be operated within the final approach course or takeoff course of any runway. The UAS will not be operated at an altitude of over

400 feel AGL. Weather minimums will be 3 miles visibi lity and 1000 foot ceiling.

• Maximum flight time for each operational flight will be no longer than 20 minutes.

• Flights will be terminated at 20% battery power re serve should that occur prior to the 20 minute flight time limit.6

• The UAS will be operated in an altitude limiting m ode of no more than 400 feet AGL

• The minimum crew for each operation will consist of th e UAS PIC and Visual Observer (if needed).

• The UAS will be operated by the petitioner weights less than 55 pounds, including photographic payload.

• The UAS will operate at speeds of no more than 25 kn ots, can hover, and can simultaneously move vertically and horizontally.

• Given the small size of the UAS and the restricted ste rile environment in which they will operate, the UAS operations adhere to the Reform Act ’s safety requirements.

The operation of the UAS, weighing less than 5 lbs., co nducted in the strict conditions as
outlined above, will provide an equivalent level of safety supporting the grant of exemptions
requested herein, including exempting the Petitioner from the requirements of Part 21 and
allowing commercial operations.

These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled
environment. As a result, they offer a much safer way t o capture aerial photography and
videography than with the traditional use of manned aircraft.

Pilot in Command and Observer Qualifications and Du ties

As the Pilot In Command I will maintain all health a nd safety regulations for PIC. My FAA issued

Private Pilot License number is 266842607. As PIC I wi ll maintain my proficiency with a minimum of 1 hour total flying time and 3 takeoffs a nd landings within 30 days in the type of UAS utilized in operations.

The PIC is responsible for all Pre-flight activities an d conducting safe and efficient operation of

the aircraft. Duties of the PIC are:

• All Pre-flight activities

• In flight operations

• Post flight activities

• Safe in flight operations in accordance to COA

• Risk mitigation to persons and property

• Flying field stability

• Aircraft maintenance

• Flight and Maintenance logs

• Required reporting to the FAA

The Observer must have the visual acuity to observe the UAS and be able to communicate clearly with the PIC either vocally or by 2 way radio . Duties of the Observer are:

• Warning the PIC of any impending obstacles in the fl ight path of the UAS

• Warning the PIC of any deviations in the planned fl ight path of the UAS

• Warning the PIC should any unauthorized personnel ap pear in the area of planned flight

• The observer will have the authority to order the P IC to terminate the flight should he feel the flight cannot be conducted safely.7

Pre-flight Requirements

The PIC will follow a comprehensive pre-flight checkli st to ensure that the UAS is in a condition of safe flight. This plan will be improved as needed t o incorporate precautions and safety suggestions issued by the manufacturer.

A. Pre-flight Inspection

1. Check that the transmitter, UAS and camera batteries are all fully charged.

2. Verify that the UAS battery is not swollen or dama ged in any way.

3. Turn the motor shafts with your fingers and verify that are smooth without excessive play or binding.

4. Verify that the propellers are mounted correctly and free from signs of damage.

5. Run finger along the edge of blade to check for an y rough edges.

6. Flex both sides of the propellers’ blades to check for hairline cracks where the blades connect in the center of the propeller.

7. Verify that the landing gear is secure and free fro m damage, broken or loose.

8. Verify that the camera is secure and clean. Inspect th e camera connections and gimbal for tears and/or signs of wear.

9. Verify that the damping absorbers are not broken a nd/or worn.

10. Verify that the Micro-SD card has been inserted an d formatted.

11. Verify that the remote camera link is enabled.

B. Power Up

1. Power on the transmitter with the flight mode set to the appropriate setting the throttle

stick down and the throttle trim at neutral.

2. Install a charged battery in the UAS.

3. Calibrate the internal compass at each new geograph ical area of flight

4. Wait for the GPS signal to be acquired, which is in dicated by a flashing green LED. It may take from 30-90 seconds to acquire a GPS signal.

5. Move the aircraft to the desired home location and orient the aircraft pointed away from the pilot and into the wind.

6. Step back approximately 15 feet (5 meters) from th e home location.8

C. Ready to Fly

1. Verify that the aircraft still has GPS lock.

2. Start the motors.

3. Verify that the motors are functioning normally, are not making any unusual noises, and are all spinning the same speed.

4. Verify that the area is still clear of obstruction s, people, power lines, etc.

5. Take off and hover about 6-8 feet above the take off point to verify that the aircraft still has a solid GPS lock. If any abnormalities are noticed ( drifting, flying in circles, etc.), land immediately and repeat the “Pre-flight Inspectio n” and Power Up” sequences.

6. Verify that the aircraft holds a steady position w hile yawing 360 degrees.

7. Verify that the aircraft responds appropriately to all controls – yaw, pitch, roll and throttle.

Post Flight Requirements

A. After Flight

1. Turn off the power switch on the aircraft.

2. Turn off the power to the transmitter.

3. Unplug and remove battery from aircraft.

4. Secure flight operations area.

Preventive Maintenance

A comprehensive preventative maintenance plan will be followed in accordance with the
manufacturer’s specifications to ensure the UAS software is up-to-date, the batteries are
in good health, and the aircraft itself is always read y for safe flight.

Public Interest

Granting this exemption would benefit the public as a whole. UAS offer a strong equivalent level of safety, a reduction in environmental impacts, and are free from the harmful emission associated with the manned aircraft that are currently u sed for aerial photography and videography. Due to the size of the UAS and the tigh tly controlled and limited airspace in9

which the UAS will operate, approval of this applicat ion presents no risk to the public. Furthermore, the public will be able to legally acqui re aerial photography and videography to help in, but not limited to, advertising yachts for sal e and use of photos and video as an aid when researching yachts for sale on the market.

Privacy

Since the areas being photographed or filmed will be on private property, accessed only after given written and/or oral consent by the property own er(s), and clear of all people, except for the PIC and the PIC’s helper(s), approval of this applicati on presents no risk to the public privacy.

National Security

Due to the size of the UAS and the tightly controlled and limited airspace in which the UAS will operate, approval of this application presents no risk to national security.

Requested Exemptions

Michael K. Martin requests exemption from the followi ng regulations as well as any additional regulations that may technically apply to the operati on of the UAS:

14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of a n airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the DJI Phantom 2 Vision Plus and the DJI

Phantom 3 Advanced under either or both of the follo wing provisions: 21.191 Experimental certificates. Experimental certifica tes are issued for the following purposes: (a) Research and development. Testing new aircraft desig n concepts, new aircraft equipment, new aircraft installations, new aircraft operating techn iques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting f light tests and other operations to show compliance with the airworthiness regulations includi ng flights to show compliance for issuance of type and supplemental type certificates, fligh ts to substantiate major design changes, and flights to show compliance with the functi on and reliability requirements of the regulations. Since the experimental certificate can be u sed for commercial purposes such as market surveys, sales demonstrations, and customer crew tr aining, we would expect that an experimental certificate would permit our commercial pu rpose as well. The aircraft will not carry persons or property, will not carry fuel, and will onl y fly under strict operational requirements. Combined with the UAS's light weight, being constructe d primarily of plastic, we propose that the UAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airwo rthiness certificate is not appropriate for this application, then we request an exemption of 14 C FR Part 21, Subpart H, and the requirement for an airworthiness certificate in genera l, citing the equivalent level of safety outlined in the previous paragraph.10

14 CFR 45.23 Display of markings; GENERAL AND 45.29 Size of marks. These regulations provide that each aircraft must disp lay "N" and the aircraft's registration number in letters at least 3 inches high. Additionall y, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. These UAS’s do not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assig ned to it by the FAA. I propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PI C (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it i s preparing for launch will be able to see the designation. Additionally, I feel that the permanent placard discusse d in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, I will display at the ground station a high contrast flag or banner that contains th e words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since th e aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyon e that observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitati ons: Pilot In Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a Pr ivate Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subpa ragraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with a ny business or employment if: (1) The flight is only incidental to that business or employment ; and (2) The aircraft does not carry passengers or property for compensation or hire. My pro posed operation requires that the PIC

must hold at least a Private Pilot Certificate with a valid drivers license from any state and since the aircraft cannot carry passengers or property, I fee l that I meet the intent of 61.113 Subparagraph (b) even though the intent of this appl ication is to conduct a business.

14 CFR 91.7 Prohibits the operation of an aircraft without an airworthiness certificate. As no such certification will be applicable in the form co ntemplated by the FARs, this regulation is felt to be inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking a nd placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. I assume that the intent of this requirement is to ensure that flight

manual information is available to the aircrew while operating the aircraft. I request an exemption to this requirement since the aircraft is not only too small to carry documentation, the

documentation would not be available to the crew dur ing flight operations. To obtain an equivalent level of safety and meet the intent of 91 .9, I propose that a current, approved UAS Flight Manual must be available to the crew at the g round station anytime the aircraft is in, or preparing for, flight.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely popu lated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, veh icle, or structure. Since the typical mission of the UAS would be photography or survey of st ructures it would be necessary to operate closer than 500 feet to the building. Operati ons will only be flown over property where permission has been obtained and careful pre-planned f light path has been performed. The aircraft will be operated at a low altitude allowing , if a power unit fails, an emergency landing without undue hazard to persons or property on the sur face. Therefore I maintain that due to the11

size of the UAS, the hazard to persons, vehicles and stru ctures is minimal compared to manned aircraft, which should be considered in granting the exemption.

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The UAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An

Above Ground Level altimeter measurement above the t akeoff point is processed within the aircraft operating system.

14 CFR 91.151 Fuel requirements for flight in VFR c onditions. The regulation provides that no person may begin a fl ight in an airplane under day-VFR conditions unless there is enough fuel to fly to the fir st point of intended landing and to fly after

that for at least 30 minutes. I feel the intention o f this paragraph is to provide an energy reserve as a safety buffer for delays to landing. These UAVs are battery operated and the maximum duration of flight from a single battery cha rge is approximately 20 minutes with a 20% reserve. Since the aircraft will never fly more than 3 /4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fue l" and ask for an equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certificatio ns required. The regulation provides that an airworthiness certificat e, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certifi cate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 3 pounds, the UAS is too small to carry documentation, does not h ave an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent le vel of safety and meet the intent of 91.203, I propose that documents deemed appropriate fo r this aircraft by the FAA will be with the crew at the ground control station and availabl e for inspection upon request. In order to identify the aircraft, I propose that the registratio n number be permanently affixed to the aircraft containing the aircraft N Number plus the word "EXPER IMENTAL" to satisfy the requirement of

14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Pre ventive Maintenance, Alterations The regulation provides that the operator is primari ly responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for re turn to service by a person authorized under 43.7" after maintenance and inspection. It is my inten tion that the PIC perform maintenance and inspection of the aircraft and "be authorized to appr ove the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of fli ght. Maintenance performed by the PIC is limited to repairing small cracks, replacing a prope ller, checking electrical connections and updating software and firmware for the on-board compu ter. All other maintenance will be performed by the manufacturer or their designated rep air facility. The PIC will document work performed in accordance with 91.417. I feel that due t o the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent lev el of safety.12

Safety and Benefits of the UAS I, Michael K. Martin will be using the UAS in a varie ty of applications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer

numerous benefits over the use of full-sized manned ai rcraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with a UAS carrying no passengers or crew creates a much greater ma rgin of safety for the pilots and crew. By granting Michael K. Martin the requested exemptio ns, the FAA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. As an experienced Private Pilo t I am committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from my commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this P etition.

Conclusion As pointed out in this application, the UASs which I wou ld use, under authorization by the US DOT-FAA, are small, light-weight devices operated wit hin the line of sight of the Pilot-inCommand (PIC), less than 400 feet above the ground an d outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location wi th aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized each flight within a radius of

this distance.

My UAS has proven capability for controlled flight. It is a device offered for general sale on the

market around the world and has often been used as Mod el Aircraft in the USA. I am certain that the studies conducted until now by the FAA, abou t Section 332, Public Law 112-95, 2014, have already provided you with the assurances on the a irworthiness of UAS such as mine.

For the foregoing reasons, the exemptions requested her ein should be granted and Michael K. Martin should be permitted to conduct UAS operations i n accordance with my manuals and all other operating parameters deemed necessary and appropr iate by the FAA. The submission of this application and its contents is the best demonstra tion that indeed it is possible to pursue the authorization process so that some UAS may be respon sibly used for legitimate commercial activities and under reasonably safe condition s.

Signed

Michael K. Martin