December 2 8 , 2015

John E. Kildea Jr. dba Brentwood Engineering LLC 2221 Saint Clair Avenue Brentwood, MO 63144 ( 3 1 4 ) 368-9228 Email: jkildea653@gmail.com

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References:

1) FAA Exemption No. 11410, Regulatory Docket No. FAA -2015-0186 in the matter of the petition of RALPH J. APEL 2) FAA Exemption No. 11341, Reg ulatory Docket No. FAA –2015–0037 in the matter of the matter of the petition of BOB SOKOLER

Dear Sir or Madam, In accordance with the FAA’s Guidelines fo r Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, I John E Kildea Jr.

, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§

**61 .113 (a) & (b), 91.7(a),**  **91.119 (c)**  **, 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a**  **)(1) & (2), and 91.417(a) & (b);**

I n order to oper ate small unmanned aircraft s y s tems (UAS) commercially in airspace regulated b y the Federal Aviation Ad ministration (FAA) for the purposes of aerial
p h otograph y, cinematography, videograph y, mapping, survey ing

, structural in spections and o th er fl ight operations that co uld be performed safely and more cost ef f ectively with the use of small UAS at low altitude within the U.S. national airspace sys tem as compared to a manned aircraft. Op erations will b e performed on ly at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and rai se awareness o f the b eneficial uses of small unmanned air
sys tems. So long as such operations are conducted within and under the conditions outlined here in o r as may b e establish ed b y th e FAA as required by Section 333. The petitioner seeks exemption from the above -m entioned FARs for the following

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

3 ) FAA Exemption No. 11728 Regulatory Docket No. FAA-2015-0850 in the matter of the petition of ALON SICHERMAN**61.113(a) & (b)** ; The petitioner requests relief in order to facilitate the utilizati on of

pilots , who hold a Sport pilot (or greater) certificate. Any pilots operating under this exemption would be required to comply with an y conditions as set forth and in a similar fashion to the previousl y granted exemptions.

**9 1**  **.7(a)** ; R elief fr o m Sectio n 91.7(a) e n titled Civil aircraft airwo rthin ess , is requested to the extent req u ir ed to allow petitioner to determine that the DJ I Phantom 3 Professional and Inspire I P r o fessional UAS s are in airworthy condition prior to every flight by ensuring that th e UAS s are in compliance with the operating docu men ts ( i.e.

, the Mo nthly Ma intenance Lo g, and DJ I Ph antom 3 Professional and I n spir e I Profession al I n struction Manual s ). Petitioner seeks the requested r elief because th e Phantom 3 Pro fessional and Inspire I UAS s do not requ ir e an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, petitioner will ensure that the DJ I Phantom 3 Professional an d

Inspire I Professional UAS s ar e in airworthy condition based upon its compliance with the operating documents (i.e., Mont hly Mai ntenance Log, and DJI Phan to m 3 Professional and Insp ire I Professional Manual s ) prior to every flight, and f urther, d etermine that the aircraft is in condition for a safe flight.

**91.119(c)** The petitioner re quests waiver to allow reasonable and responsible oper ations in areas of subdivisions and neighborhoods if required.

**91.121** This is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information.

**9 1** 

**. 151(a)**  **(1)** The UAS provides battery power remaining in percent to the PIC. The UA batt eries provide approximately 1 7 mi nutes for Inspire I Professio n al and 23 Min u tes for Phantom 3 P rofessional, of powered flight. Information provided in the operating documents d iscusses procedures regarding remain ing battery power management. Those documents c ontain a condition in which the PI C will initiate a landing procedure when b attery remaining reaches a specified level. Given the limitations on proposed operations and the l o cation of those proposed operation s, The FAA found th at a reduced minimum
power reserve for flight in d ay time VFR conditions was reasonable.

**9 1.405(a); 91.4**  **0 7**  **(a)(1); 91.409 (a )**  **(1) & (2); 91.41 7**  **( a) & (b)**  **;** Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) o nl y apply to a ircraft with an airworthiness certificate, the petitio ner requests relief from these Se ctio ns because the DJ I Ph antom 3 Professional an d Inspire I Professional UAS s d o not
req u ire an airworthiness certificate. The DJ I P hantom 3 Professional and In spir e I Pr o fessional UAS s meet the co n ditions of FMRA Section 333 for operatio n without an airworthiness certifica te. According l y , the petitioner will use trained technicians to perform maintenance, a lterations, or pr eventive mainten ance o n the UAS u sing the methods, techniques, and practices prescribed in the UAS oper ating documents ( i.e., Mo n thly Ma intenance Log, and DJ I Phantom 3 Professional and Insp ire I Professional I nstruction Manual s ). Further mo re, th ep etitioner will document and maintain all maintenanc e records for the DJ I Phantom 3

Professional and Inspire I Professional UAS s

.

**The UAS**

The DJI Phantom 3 Professional and Inspire I pofessional a re both highl y successful consumer grade small rotorcraft in the q u adcop ter configuration with an a dvertised weigh t of less than 4 6 Ounces (1280 g) designed primarily to c arry aloft a h igh d efinition camera. B o th r otocraft ha ve an advertised maximu m speed of less than 30 knots (16m/s) and a maximum climb rate of less than 1200 feet per minute (5 m/s). They are p o wered by four electric motors with a distance between motors of less than 14 inc hes (350mm) Both rotocraft utilize an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global po sitioning sy stem (GPS) to maintain geospatial orientation and position. Bo th ro tocraft are controlled primaril y through an FCC certified ra dio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the op erator and/or PI C to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery , and control camera angle. Both rotocraft ha ve failsafe modes of operati on for either loss of RC or GPS signal. Altitude can be limited by the onboard f ligh t controller and maximum altitude can be preprogrammed b y the PIC. Battery life limits flight times to appr oximately b etween 1 7

- 2 3 minutes depending on Model

. The

o n b o ard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low batter y state. An automatic termination of flight and landing will b e initiated when the battery re aches a predetermined low state. It is anticipated that f lights will usually last less than 10 minutes. More information is available on h ttp://www.dji.com/product/

**Public interest**

U s e of the UAS in lieu of a ma n n e d a i r c raft would enhance s afety a n d r e d uce the environmental impact as compared to similar operations conducted with manned aircraft

o f g reater p r o p o r t i o n s , c arry ing a c r e w a n d flammable fuel. Additionall y, use of the U A S in order to facilitate commer c e coul d l e a d t o economic growth. Ope ration s for this
p e t i t ion w ill ena b l e s e r v i c e f o r propert y owne r s o r t h eir designees se e k i n g an enhance d
pe r spective for characteristi c s , a m e n i t i e s , a n d b e n e f i t s o f t h ei r desired photographic

s ub je c t s t h a t c a n n o t b e d i s p l a y e d t h r o u g h g round l evel videogra p h y / p h o t o g r a p h y

. A erial
p h o t o g r aph y is a valuable ma r k et i n g tool that c a n l e a d t o i n c r eased c o m m e r ce and

e n h a n ce per s o n a l phot o g r a p h y

. A erial surveying and inspections can increase work site effic ie n c y , im prove volumetric e s t i m a t i o n s a n d r e du c e risks. The pe t itioner w i l l pr o v ide cl i ents with photographic data for these purposes on a ‘for hire’ basis acti n g as an i n d e p e n d e n t cont ractor. A visua l o b s e r v er will be ut i l iz e d

. L i a b i l i t y i n s urance will be

o b t a i ned commensurate w ith t h e g r anti n g o f t h i s r e q u e s t f o r e x e m p t i o n

. F light data i n c l u d i n g U A flight time, Control Unit operation time, incident, accident, and details

c on c e r n i n g a n y deviations from normal operations will be available to FAA for use in collecting data r e g a r d i n g t h e us e o f U A S a s p a r t o f t h i s a p p l i c at i o n

. T h i s d a t a m ay b e

su b m itted to FAA v i a t r a d i t i o na l means, e.g. COA Monthly R e p o rt s , o r ot h er means a s

r e qu i red.**Conclusion**

The petitioner is requesting this exemption for the purpo ses of “aerial photograph y, cinematograph y, videography , mapping, survey ing, structural inspections and other flight operations”. The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptions. The petitioner 's b u siness model is based on the idea of offering ad hoc small UAS services to individuals

or co mpanies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby

.

Respectfully submitted

John E. Kildea DBA Brentwood Engineering LLC

URL Links for attachment files over 30 MB :
1) DJI Phantom 3 Professional Information link including manuals and specifications : http://www.dji.com/product/phantom-3-pro/info

2 ) DJI Inspire 1 Professional Information link including manuals and specifications : http://www.dji.com/products/inspire