Marc T Mascarelli

5662 Eichen Circle West Ft Myers, Fl. 33919 Ph: 239

- 565
- 7838 Email: marckymarc12@aol.com RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 1) Private Pilot Airplane (PAR) Airman Report References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA
–2014
–0508 in the matter of the petition of ADVANCE D AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC 4) FAA Exemption No. 11437 Regulatory Docket No. FAA20150221 in the matter of the petition of MARCUS D MELHUS

Dear Sir or Madam, 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, I Marc T. Mascarelli, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§91.119(c)

91.121 91.151(a) 91.407(a)(1) 91.409(a)(1) 91.409(a)(2) 91.417(a) & (b) 14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R 61.113 a+b 14 C.F.R. 61.133 a 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.405 (a) In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Avi ation Administration (FAA) for the purposes of aerial photography, cinematography, videography, roof inspections, real estate, and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude w ithin the U.S. national airspace system as c ompared to a manned aircraft. I am a Florida State certified HomeInspector (primary request) in need of UAS to perform roof inspections and for other related real estate

purposes. C urrently employed for 25 ye ars in the Fire Department, current title Battalion Chief, operations may also be in support of local fire departments and rel ated emergency service agencies ( Non

-governmental use private contractor) , focusing on pre

- incident planning and imaging tha t would form the basis for incident action plans in the event of a real emergency
. All o perations stated above will be performed only at the request of and with the authorization and permission of clients (municipalities) or their authorized agents in order to improve incident pre

- planning and raise awareness of the beneficial uses of small unmanned air systems. 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 Se ction 333. The conditions identified and proposed by the petitioner are drawn from references 1

- 3. The petitioner is also aware that before any commercial flight operation, in addition to acquiring a sec 333 exemption, the petitioner must also register their UAS and acquire an N number through the FAA. The FARs The petitioner seeks exemption from the above mentioned FARs for the following
reasons; 61.113(a) & (b) ; The petitioner requests relief in order to facilitate the utilization of an experienced UAS operator with the addition of a trained observer. All pre

-flight inspection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely integrating civil UAS operati on in the National Airspace System. 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closerthan 500 feet to the ground may require that the UA be operated closer than 500 feet to essential

persons, or objects that would no t be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. The petitioner requests waiver for this condition to allow reasonable and
responsible operations in areas of subdivisions and neighborhoods if required. The petitioner will primarily operate the UAS between ground level and 200 feet. The UAS will be operated over designated properties with the consent of the local municipality or their designated agent and while maintaining a safe distance from persons. The petitioner will compile flight data from the logs. This data may assist the FAA in development of regulations for commercial operations in low

- risk, controlled environments. 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 information. 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, 108 08, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. 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 daytime VFRconditions was reasonable.

91.405(a) ; 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to insp ect 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 and limitations specified, describing the requirements for mai ntenance, inspection, and recordkeeping, were sufficient to ensure that safety woul d not be adversely affected. The DJI Phantom 3 Advanced is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through 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 PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller (maint aining default presets at 400ft)
. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of fli ght and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last l ess than 12 minutes. Risk mitigationThe petitioner has reviewed FAA exemptions reference’s 1

- 3 Conditions and Limitati ons

section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components. These documents will be made available to the FAA and SoT to assist in future implementation of safety standards and regulations. The petitioner will only operate the UAS over designated properties with the clients consent. Flight plans will be predetermined to limit the UASs flight time and limit safety conc erns. The petitioner will take into account distance from persons and potential flight obstacles prior to operating the UAS. UAS operation will always be within VLOS of the PIC (certified pilot)
. The UAS will not be flown within a 5 mile range to any airpo rt or heliport. Public Benefit and Safety Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flam mable fuel. With the ability to easily and cost effectively gain a perspective of complex and possibly high risk environments, fire departments can more effectively develop pre

- plans to mitigate any situations that arise. Moreover, the ability to periodica lly review building roof modifications and loads significantly improves situational
awareness . Operations for this petition will enable fire departments to gain an enhanced perspective for characteristics, exposures and hazards associated with a particular property that cannot be gained through ground level inspection. Aerial surveying and inspections can increase planning efficiency, improve resource estimations, and reduce risks to pe rsonnel and property. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. For the purpose of home roof inspections, UAS photographsprovides assurance to the client to avoid the inspector and/or clients from having to access the roof

which has a high risk of a fall resulting in serious injury or death. Flight data including UA flight time, Control Unit operation time, incident, accident, and details concerning any dev iations from normal operations will be available to FAA for use in collecting data regarding the use o f UAS as part of this application. This data may be submitted to FAA via traditional
means or other means as required. Summary The petitioner is request ing this exemption section 333 of the FAA Modernization and Reform Act of 2012 91.119(c), 91.121, 91.151(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) & (b) 14 C.F.R. Part 2, 14 C.F.R. 45.23 (b), 14 C.F.R 61.113 a+b, 14 C.F.R. 61.133 a , 14 C.F. R. 91.7 (a), 14 C.F.R. 91.9 (b) (2), 14 C.F.R. 91.103 , 14 C.F.R. 91.109, 14 C.F.R. 91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151 (a), 14 C.F.R. 91.203 (a) & (b), 14 C.F.R. 91.405 (a) for the purposes of “aerial photography, v ideography, real estate, roof in spections, and other flight ope rations possibly including private c ontractor fire department preplanning. The petitioner's business model is based on the idea of offering small UAS services to clients who wish to employ these services as a safe, effecti ve, and legal option to enhance their operations. By providing this service to multiple clients, the petitioner can ensure adherence to standards and protocols and can develop and refine generally applicable safety guidelines and processes. The primary purpose of seeking this exemption is to obta in the capability to offer services while remaining in compliance. The petitioner has been in the Professional Fire Service for 25 years . Currently a Chief Officer, I am familiar and currently hold th e highest standard to public safety. The petitioner also has 20 years of experience in the radio control model aircraft fixed wing, rotorcopter, and quadcopter hobby. In addition , the petitioner h as completed Ground School Private Pilot Course and passe d the FAA Airman written exam giving me a clear understanding of the FAA guidelines and their application to safety.
Respectfully submitted Marc Mascarelli