Edward F. Beck
1910 Brookmonte Dr SE Puyallup WA 98372 Tel: (253) 831

- 8905
Email: ed@edbeckphotography.com
Private Pilot Certificate Number : 3448860

Ed Beck Photography LLC petitions for a Grant of Exemption so that the company can conduct aerial videography and cinematography to enhance academic community awareness for those individuals and companies unfamiliar with the geographical layout of the Puget Sound area and to aug ment real estate listing videos. Specifically we request an exemption from part 21, subpart H; and Sections 45.23(b),61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91 .151 (a), 91 .203(a) and (b), 91.405(a), 91.407(a)(1 ), 91.40 9(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). These flights would be conducted using 3D Robotics Solo with a GoPro camera

.
With Safety being our primary goal we look at this operation as a safer alternate to operating a larger petroleum powered aircraft requiring airborne crew members. To ensure that we can meet those requirements we will make sure that all our PICs have at least a private pilots certificate with either a current FAA class 3 physical or a driver’s license . In addition we will insist that all PICs go through our ground training program that will cover the operation of the specific UAV they will be operating, weather requirements, UAV system operations both normal and emergency. The training will also cover the importance of documenting both the flight hours of the PIC and the UAV. Special emphasize will be put on documenting any and all maintenance discrepancies and the importance of properly documenting the resulting corrective action prior to any flight. I n addition, we believe that every PIC
needs to have accumulated at least 25 hours of UAS time of which at least 10 hours would be in multi rotor UAVs and have at least 5 hours in make/model prior to commercial operations. To maintain proficiency we will ma ke sure the PIC makes at least 3 take offs and landings within any 90 day time frame and all these requirements will be documented in the Pilots log book. To ensure we do not interfere with any other manned aircraft we will not fly above 2 00' AGL or within 5 miles of any airport unless we are in radio contact with the control tower. To ensure all know of our presence we will post all flights on NOTAMS and will advise all local residence of impending flights. On the day of the flight we will post signage ind icating that a UAV flight is in the immediate area. As for the actual UAV operation we will insist on that all PICs complete a preflight safety check of the UAS that will ensure all components of the system work as required.

Name and Address of t he Petitio ne r.

The name and address of the Petitioner and point of contact is:

Edward F. Beck
1910 Brookmonte Dr SE Puyallup WA 98372 Tel: (253) 831

- 8905Email: ed@edbeckphotography.com
Private Pilot Certificate Number : 3448860Part 21 prescribes the procedural requirements for issuing and changing design approvals, productions approvals, airworthiness certificates, and airworthiness approvals.

Section 45.23(b) prescribes that when marks include only the Roman capit al letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental, n or "provisional," as applicable.

Because of the si ze of the aircraft we propose to install the "N" on the f uselage but do not think there is adequate space to also place any of the categories mentioned

Section 61 .113( a) and (b) prescribes that

a) No person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passeng ers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employ ment 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.

Since we will not be carrying any passengers or property for compensation we feel a private pilot

can ca rry out the responsibilities of the PIC.

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy
condition.

An exemption is requested to 91.7(a) because the UAV does not have to receive an airworthy condition by the FAA

Section 91.7(b) prescribes that the pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when un airworthy mechanical, electrical, or structural conditions occur.

We will terminate any flight when the aircraft becomes un airworthy with mechanical, electrical or structural conditions. There is no exception.Section 91.9(b)(2) prohibits operation of U.S.

- registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

There is no FAA approved manual for the 3D Robotics Solo but we are submitting the fo llowing that w e feel will suffice. Flow Chart, quick start check list, user manual and advanced check list.

In addition we have prepared our own company operating manual and finally we have created a check list to ensure a safe operation.

Section 91.1 03(b) prescribes that a pilot shall for any flight, become familiar with runway lengths at airports of intended use, and takeoff and landing distance information.

The 3 D Robotics Solo does not use any runway for take off and the company policy is that the 3D
Robotics Solo will remain clear of all ramps, taxiways and runways associated with any airport.

Section 91.1 09(a) prescribes, in pertinent part, that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight in struction unless that aircraft has fully functioning
dual controls.

The 3D Robotics Solo does not have dual flight controls and all instruction is via the one controller. We therefore request an exemption from this requirement

Section 91.119 prescribes tha t, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes

a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

We will not operate the Phantom 2 near any power lines, light posts or any other powered
obstacle

b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest o bstacle within a horizontal radius of 2,000 feet of the aircraft.

We will not operate the 3D Robotics Solo over any congested areas.

c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated are as. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Because of small size of the 3D Robotics Solo (3.3 lbs) and the fact there is no fuel on board we feel as how we offer no risk to flying less than 500 in other than congested areas. We would like to operate like powered parachutes in that we will ensure that we do not present any hazard topersons or property on the surface. In addition we will ensure we have permission from the owner of a ny vehicle or property prior to getting within the 500 ft area.

d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

1) A helicopter may be operated at less tha n the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and 2) A powered parachute or weight

- shift

- control aircr aft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set " ... to the ele vation of the departure airport or an appropriate altimeter setting available before departure."

The 3D Robotics Solo does not have a barometric altimeter but uses GPS signals to compute altitude. The
3D Robotics Solo has a setting for maximum AGL altitude, the default of which is 150’. We will set the
maximum altitude at or below 200’

.
Section 91.151 (a) prescribes that no person may begin a flight in an airplane under VFR conditions unless (considering wind and foreca st weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, (1) during the day, to fly after th at for at least 30
minutes.

Since the 3D Robotics Solo does not carry fuel but uses battery po wer we request the following. The battery on the 3D Robotics Solo App Interface shows flight battery percentage remaining. When the flight battery percentage remaining reads as 30% power and we u se that as the planning to return for a safe landing. Most o f our flights will not exceed 10 min ute s in flight and since the battery has a normal 25 minute range this 30% factor should provide a safe return point. We will ensure that all flights
consider winds in determining the return point as they could have a he ad wind on return.

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration
certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in § 47.31 (c).

An exemption is requested for the airworthiness requirement since the 3D Robotics Solo does not have an
airworthines s certificate

.Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Since there is no requirement for an airworthiness certificate for the 3D Robotics Solo this requirement would not be appropriate. In addition because of the size of the aircraft there is just not a place to display the certificate.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of t he same section, have discrepancies repaired as prescribed in part 43 of the chapter.4

There is no approved maintenance program for the 3D Robotics Solo but we will ensure that it goes through a complete overhaul by an approved maintenance personnel annually.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized un der§ 43.7 of the same chapter.

After any maintenance that requires change of engine or propeller that aircraft will undergo a test flight by the PIC in a remote unpopulated area to ensure the aircraft is operating safely

Section 91.409(a)(2 ) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

After any maintenance that requir es change of engine or propeller that aircraft will undergo a test flight by the PIC in a remote unpopulated area to ensure the aircraft is operating safelySection 91.417(a) and (b) prescribes, in pertinent part, that

a) Each registered owner or operator shall keep the following records for the periods specified i n paragraph (b) of this section: 1) Records of the maintenance, preventive maintenance, and alteration and records of the
1 00

- hour, annual, progressive, and other required or approved inspections, a s appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

i. A description (or reference to data acceptable to the Administrator) of the work performed; and
ii. The date of completion of the work performed; and
iii. The signature, and certificate number of the person approving the aircraft for
return to service. 2) Records containing the following information:
i. The total time in service of the airframe, each engine, each propeller, and each

rotor.
ii. The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.
iii. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
iv. The curre nt inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

v. The current status of applicable airworthiness directives (AD) and safety
dire ctives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
vi. Copies of the forms prescribed by§ 43.9( d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. b) The owner or operator shall retain the following records for the periods prescribed: 1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. 2) The records specified in paragraph (a)(2) of this section shall be retained and transferred
with the aircraft at the time t he aircraft is sold. 3) A list of defects furnished to a registered owner or operator under

We will maintain an aircraft logbook that will refl ect all flight t1me on the UAV

. A ny

m aintenance performed on the UAV. There are no li fe

- l i m i ted parts on the 3D Robotics Solo

. N o system of AD . If we are notified by the manufacture that there is a discrepancy we w i ll rectify i t and annotate prior to the next flight if it relates to fli ght safety

.§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for
return to service.

Ed Beck Photography LLC provides the following supporting documentation including:

1) Supplemental Response for Petition, 2) 3D Robotics Solo User Manual including:

a. Preflight Checklist
b. Flight Instructions

c. Landing Instructions
d. 3D Robotics Solo S pecifications.

e. 3D Robotics Solo Operating Parameters 3) R estricted areas map of planned flight area.

Unmanned Aircraft System Flights are planned primarily for Pierce County in Washington State, with some operations in King, Kitsap, Thurston and Lewis counties. A map of the proposed area of operation is included which
includes no

- fly zones.

Ed Beck Photography LLC plans to operate a UAS, the 3D Robotics Sol o , which is comprised of an unmanned aircraft (UA ) and a transportable ground station. The 3D Robotics Solo is referred to as a quad

- copter with a gross weight of 3 .3 pounds and a payload capacity of 1.1 pounds . It is equipped with
four rotors that are dri ven by electric motors powered by batteries. The UA has a maximum airspeed of 55 mph

. Ed Beck Photography LLC plans to attach a small ultra

- lightweight GoPro 4 camera to t his UA and operate the UA over various areas in Western Washington to include Pierce, King, Kitsap, Thurston
and Lewis counties to enhance community awareness and augment real estate listing videos. Ed Beck Photography LLC makes the following representations of operational enhancements which he proposes to abide by to ensure this exemption will provide a level of safety at least equal to existing rules:

Ed Beck Photography LLC :

• Will o nly operate in reasonably safe environments that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; and

• Will c onduct extensive preflight inspections and protocols, during which safety carries primary importance.

• S tates that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by him, an exemption from 14 C FR part 21, Subpart H (Airworthiness Certificates) and§ 91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11
and Section 333 of P.L. 112

- 95 (Section 333).

Petitioner requests an exemption from § 45.23 Marking of the aircraft because his UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, he states that two

inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimallettering requirement. Regardless of this, Ed Beck Photography LLC states that he will mark his UAS in the largest possible lettering by placing the word "Experimental" on its fuselage as required by § 45.29(f) so that he or anyone assisting him as a spotter will see the markings.

The petitioner states that an exemption from §§ 91.405(a), 91.407(a)(1 ), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be requi red and should be granted since they only apply to aircraft with an airworthiness certificate. However, Ed Beck Photography LLC states as a safety precaution he will perform a preflight inspection of his UAS before each flight as outlined in his operating documents.

UAS Pilot in Command (PIC) Ed Beck Photography LLC asserts that under§ 61.113 (a) and (b) private pilots are limited to
noncommercial operations, however he can achieve an equivalent level of safety as achieved by current regulations because his UAS does not carry any pilots or passengers. Further while helpful, a commercial pilot license will not ensure remote control piloting skills. We believe that the risks of operating a UAS
are far less than the risk levels inherent in the commercial activi ties outlined in 14 CFR part 61, et seq., thus he requests an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in command.

Regarding UAS operational training, the Ed Beck Photography LLC will fly numerous practice flights in

remote a reas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of his UAS' performance under different temperature and weather conditions. He further
states that he will practice computerized simulated flig hts to maintain adequate skills and response
reflex time. The PIC for Ed Beck Photography LLC currently holds an FAA Private Pilot license and a valid driver’s license (see a ttach ed )

UAS Operating Parameters

Ed Beck Photography LLC will abide by the following additional operating conditions under this exemption:

• Operate the UAS below 2 00 feet an d within a radius distance of 1 000 feet from the controller to both aid in direct li ne of sight visual observation;

• O perate the UAS for 3

- 7 minutes per flight;

• L and the UAS prior to the manufacturer's recommended minimum level of battery power;

• O perate the UAS only within visual line of sight (VLOS);

• U se the UAS' global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;

• C onduct all operations under his own personal and flight safety protocols (including posting a warning sign reading: "Attention Aerial Photography in Progress

- Remain Back 150 feet'')

con tained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance his safety protocols;

• C ontact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information;

• A lways obtain all necessary permissions prior to operation; and• H ave procedures in place to abort flights in the event of safety breaches or potential danger.

Ed Beck Photo graphy LLC states that§ 91.7(a) prohibits the operation of an aircraft without an
airworthiness certificate. Ed Beck Photography LLC asserts that since there is currently no certificate applicable to his operation, this regulation is inapplicable. 91.9(b)( 2) requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board his aircraft and given its size, this regulation is inapplicable. Ed Beck Photography LLC can maintain an equivalent level of safety by
maintain ing a safety/flight manual with the UAS ground station.

Public Interest Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business o wners, its expense has
been cost

- prohibitive. Granting this exemption to Ed Beck Photography LLC would allow us to provide this service at a much lower cost. Further small UAS will pose no threat to the public given its small size
and lack of combustible f uel when compared to larger manned aircraft. Operation of this UAS will minimize ecological damage and promote economic growth by providing information to companies looking to relocate or build in the Puget Sound area.

Edward F. Beck Owner, Chief Pilot

E d Beck Photography LLC
1910 Brookmonte Dr SE Puyallup WA 98372
253

- 831

- 8905 ed@edbeckphotography.com

## Appendix

Solo Operating Parameters

Estimated flight time up to 25 minutes*

Default maximum altitude 150 ft. (46 m) above ground
Range .5 miles*** (.8 km) Payload capacity 1 lb. (450 g) Cruise speed 18 mph (8 m/s)
Maximum speed 33 mph (15 m/s)****
Wind speed limitation 25 mph (11 m/s)
Operating temperature 32° F

- 113° F (0° C to 45° C)

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style, and pilot skill. Listed flight time applies to elevations less than 2,000 ft above sea level. **See Section 7.7 to adjust maximum altitude. ***Depending on environmental conditions ****This top speed corresponds to Solo when operating in Fly mode. Maximum speeds for advanced modes may vary, see Section 7.1 for more information.

Solo Specifications

Autopilot: 3DR Pixhawk 2 Flight code: ArduPilot Copter

Control: 3DR Solo Controller

Wireless communication: 3DR Link 1 .0

Frequency: 2.4 GHz Height: 10 in. (25 cm)
Motor

- to

- motor dimension: 18 in. (26 cm)

Propulsion: 880 K motors, two clockwise rotating motors and two counterclockwise rotating motors Propeller: 10 in. x 4.5 in. (25 cm x 11.4 cm) Weight with battery: 3.3 lbs. (1.5 kg)

Controller battery life: 3 hours Extended controller battery life: 6 hours Controller battery: Li

- ion 2600 mAh 7.2 Vdc (5200 mAh for extended battery)Power: Electric (rechargeable lithium polymer battery) Battery: Lithium polymer, 5200 mAh, 14.8 Vdc Battery weight: 1 lb. (.5 kg) Estimated flight time: 25 minutes*

Maximum altitude: 328 ft. (100 m) Range: .5 miles** (.8 km) Payload capacity: 1.1 lbs. (500 g) Cruise speed: 5.7 mph (2.5 m/s) Maximum speed: 55 mph (25.5 m/s)
Maximum climb
rate: 11 mph (5.0 m/s)

Maximum descent
rate: 5.5 mph (2.5 m/s)

Headwind limitation: 25 mph (11 m/s)

Crosswind limitation: 25 mph (11 m/s)

Camera: Streaming video compatible with GoPro® HERO 3, 3+ or 4 Full compatibility with GoPro® HERO
3+ or 4 Solo app compatibility: iOS 8.0 or later / Android 4.3 or later

Operating Temperature 32° F

- 113° F (0° C

- 45° C) Operating relative humidity: 0

- 85% RH

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style, and pilot skill. Listed flight time applies to elevations less than 2,000 ft above

sea level. **Range varies with location, antenna orientation, background noise and multi

- path.