December 11, 2015

U.S. Department of Transportation Docket Managements System 1200 New Jersey Avenue SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

Dear FAA/FSS representative, This letter is a formal request for exemption for the petitioner, Patrick S. McCurry, a licensed helicopter pilot, from Federal Regulations CFR 14 § 61.23(a) and (c), CFR 14 § 61.101(e)(4) and (5), CFR 14 § 61.113(a), CFR 14 § 61.315(a) and (3), CFR 14 § 91.7(a), CFR 14 § 91.119(c), CFR 14 § 91.121, CFR 14 § 91.151(a)(1), CFR 14 § 91.405(a), CFR 14 § 91.407(a)(1), CFR 14 § 91.409(a)(1) and (2), and CFR 14 § 91.417(a) and (b) for commercial use of a UAS in accordance to the FAA Modernization and Reform act of 2012. It is in the public interest to grant this request for several reasons. The video and photos from the UAS are used to promote a product or service of a business, bring new perspective to a video project, and showcase real estate properties in an innovative way. The UAS is becoming a vital asset to video productions by adding a new, unique vantage point. Since a small UAS is much more accessible and easier to operate than a helicopter, they can replace helicopters for many video applications. Using a small UAS in place of a helicopter when possible substantially reduces risk of injury to persons or damage to property, especially if operation is in a confined area. Aerial views of properties can be beneficial to the real estate market by bringing potential buyers to local communities. The UAS planned to be used are the DJI Phantom 2, DJI Inspire, or DJI S1000 weighing less than 55 pounds. The UAS to be used will be dependent on the purpose and surrounding environment most suitable for that particular UAS and job (i.e. a small UAS will be used indoors). The UAS will be used primarily for the purpose of closed-set motion picture and television filming, real estate, and data acquisition.

Regarding the Unmanned Aircraft System The UAS has several fail safe features which increase safety. A warning light is programmed to flash and audible tone sounds when the battery level is at 30%. The UAS will be immediately landed when the fail safe lights and sound are active to provide abundant time to safely maneuver the UAS to a designated landing zone and safely land. The UAS is also equipped with a feature that automatically lands if battery power is exhausted, preventing anuncontrolled crash due to low battery power. Other safety features include a “return to home” feature which is activated if UAS communication or GPS signal is lost. The DJI S1000 has redundancy to the effect that if one of the eight props is disabled the S1000 is still able to continue stable flight and safely maneuver to the landing zone. DJI equipment also uses software that prevents the UAS from being flown in “No fly zones”. An on screen display is used to receive live data from the UAS allowing the PIC and an observer keep the UAS within the altitude and speed limitations. The on screen display information also contains the UAS heading as well as distance from the point of origin that may be helpful for navigation and orientation purposes. Flight modes are also available on each UAS. During all operations, the UAS will be kept in attitude or GPS modes, adding an additional layer of safety and stability to the UAS platform. Attitude mode keeps the UAS level to prevent the aircraft from flipping over and GPS mode keeps the aircraft from drifting unexpectedly with the wind. The UAS (DJI Inspire and S1000) also have flight modes that can be activated in flight to bring the UAV back to it's point of origin, regardless of the orientation of the UAS by pulling back on the “cyclic” control, which is also helpful in the event of PIC disorientation. All control and video transmissions will be made on 2.4 GHz radios, keeping the UAS operation from interfering with other signals and equipment as well as keeping foreign signals from interfering with the drone flight. Any frequencies prohibited by the FCC will not be used.

Regarding the Unmanned Aircraft PIC The PIC is an FAA licensed airman with with a well rounded knowledge of aviation procedures, operations, and rules. The PIC will have either an FAA issued airman medical certificate or U.S. driver's license available upon request.

Regarding the Operation of the UAS Operations will be conducted in a manner that matches or exceeds the safety of any other commercial aircraft. Flights will only be conducted away from crowds and persons not participating in UAV operation and in a controlled space where the UAS is permitted to be flown. A visual observer will also be present to help keep track of the UAS and assist the PIC and verbally communicate at all times. An aviation transceiver will also be available so the PIC/VO has the ability to check wind/weather conditions or listen for approaching air traffic for additional safety. All operations will be conducted at least 500 feet from non participants and obtain appropriate permission from participants and property owners where the flight operations are conducted. The PIC of the UAS will give way to any manned aircraft or aviation operations. All UAS flights will be conducted below 400 feet AGL, at least 500 feet below clouds, 2,000 feet horizontally from clouds, and within visual line of site of the PIC and observer. Operations will be conducted at daytime in VFR conditions and at least 5 nautical miles from any airport, heliport, or any other airport reference point denoted in the FAA Airport/FacilityDirectory unless a letter of agreement with that airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. Prior to each flight, a preflight examination of the UAS will be preformed and determined to be in a condition for a safe flight. Bolts and nuts will be checked for tightness and any torque seal checked for breaks or cracks. Propellers and components will be secure and checked for tightness. The UAS frame will be visually checked for any cracks or structural damage. A test flight will be conducted if any maintenance is done or components are replaced on UAS. A briefing will also be conducted before flights with participating parties. The operator will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the UAS and it's components. UAS flights, maintenance, repairs and any damage will be logged in a log book.

Thanks for your consideration,

Patrick Sean McCurry