August 23, 2015

Northern Technical Services Michael J. Boilard 220 East Hill Road Brimfield, MA 01010 508

- 531

- 5910 Mboilard3392@charter.net
U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave SE Washington, DC 2059 RE: Exemption Request Section 333 of the FAA Reform Act of 2012
**Attachments:** 1) DJIInspire User Manual v1.2

- Li nk HERE (File too large to upload) 2) DJIInspire Maintenance Manual v1.0 3) DJIInspire Safet y Guidelines v1.0 4) DJIPhantom 3 Professional User Manual v1.2

- Link HERE (File to large to upload)
**References:** 1) FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the petition of DOUGLAS T RUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

–2014

– 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA

- 2014

- 0355 in the matter of the petition of FLYING CAM I NC Dear Sir or Mad am, In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, Michael J. Boilard of Northern Technical Services, referred to hereafter as the petitioner, request exemp tion from the following sections of Title 14, Code of Federal Regulations: 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 91.409(a)(2); 91.417(a) & (b);
Inorder to operate small unmanned aircraft sy stems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography , cinematography , videography , mapping, pipeline surveying, inspections and other flight operations that could be performed safely and mor e cost effectively with the use of small UAS at low altitude within the U.S. national airspace sy stem as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial usesof small unmanned air s ystems. So long as such operations are conducted within and under the

conditions outlined herein or as may be established by

the FAA as required by

Section 333. The conditions identified and proposed b y the petitioner are drawn from references 1

- 3.

**The FARs** The petitioner seeks exemption from the above mentioned FARs for the following reasons; 61.113(a) & (b); The petitioner reques ts relief in order to facilitate the utilization of pilots, who hold a PRIVATE 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 previously granted exemptions. 91.119(c) As discussed in Ex emption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may r equire that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible w ithout additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely

p opulated”. The petitioner requests waiver for this condition to allow reasonable and responsible oper ations in areas of subdivisions and neighborhoods if required. 91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude infor

mation. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for day time, VFR conditions. The UAS provides battery

power remaining in percent to the PI C. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, the FAA found that a reduced minimum power reserve for flight in day time VFR conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exempt ion 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner’s operating documents and the conditions an d limitations specified, describing the requirements for maintenance, inspection, and record keeping, were sufficient to ensure that safet y would not be adversely affected.

Page **2** of **5 The UAS** 

The petitioner plans on utilizing separate, but similar airframes. The DJ I In spire 1and DJ I Phantom 3 Professional. These airframes are a "pro

- sumer" grade small rotorcraft in the quadcopter configuration powered b y electric motors each. Individual Specifications for the different airframes are located in the table below. These airframes utilize an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning sy stem (GPS) to maintain its geospatial orientation and position. It is controlled primarily throu gh an FCC certified radio control (RC) unit. Real time video and telemetry

information is transmitted back to a ground control station allowing the operator and/or PI C to monitor battery level, GPS signal strength, altitude (AGL), distance from PI C, camera imagery , and control camera angle. Failsafe modes of operation for either loss of signal (RC or GPS) or battery level. Altitude is limited and pre

- programmed to not exceed 400ft AGL. Battery life limits flight times to approximately

20

- 25 minutes for each airframe. The onboard flight controller will warn the pilot via telemetry

and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. Itis anticipated that flights will usually last less than 10 minutes. More information is available in product manuals which are Attachments 1 through 4. UAS Airframe Specifications DJII nspire 1 DJIPhantom 3 Weight (Pounds) 6.47 2.82 Dimensions (inches) 17.25x17.75x11.85 23.23 (Diagonal) Max Speed (Knots) 43 30 Temp Range (°C)

- 10° to 40° 0° to 40°

**Risk Mitigation** The petitioner has reviewed FAA exemptions reference’s 1

- 3 Conditions and L imitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safet y. A preflight checklist has been developed and employ ed to ensure that the UA airworthiness will be verified before launch. Airwor thiness will be maintained b y performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure

- prone components. The petitioner requests that in a manner similar to reference 3, he be allowed to opera te within 5 miles of an airport provided that; “The UA may

not operate in Class B, C, or D airspace without written approval from the FAA. The UA may

not operate within 5 nautical miles of the geographic center of a non

- towered Page **3** of **5**airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement

with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required b y t he operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.” Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within Class B airspace are not requested due to the lack of Mode C transponder.
**Public Interest** Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact a s compared to similar operations conducted with manned aircraft of greater proportions, carryi ng a crew and flammable fuel. Additionally , use of the UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for propert y owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be display ed through ground level videograph y/

photography . Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photograph y. Crop surveying applications could lead to decreased use of pesticides and fertilizer and conservation of water as well as increased crop yi elds and decreased c osts. Aerial surveying and inspections can increase work site efficiency , improve volumetric estimations and reduce risks. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contract or. A visual observer will be utilized. L iabilit y insurance will be obtained commensurate with the granting of this request for exemption. Flight data including UA flight time, Control Unit operation time, incident, accident, and details concerning an y dev iations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as required.
**Conclusi on**  The petitioner is requesting this exemption for the purposes of “aerial photograph y, cinematography, videography, mapping, pipeline surveying, inspections and other flight operations”. The reason for such a general and broad based request is that the p etitioner 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 pe titioner's business model is based on the idea of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby . The petitioner’s own market resear ch shows pent up demand for these services currently exists in the real estate market and other markets are just beginning to emerge. The petitioner has identified Universities and other Agencies that could benefit from the operation requested in this appl ication.

Page **4** of **5**A quick internet search will show that many are currentl y operating similar UAS in exactly this fashion without, it is assumed, FAA authorization. The petitioner has refrained from engaging in commercial use of the UA S. The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance. Thank y ou in advance for y our time and consideration. Kind Regards,

Michael J. BoilardPage **5** of **5**