Submitted On-line www.regulations.gov on August 19, 2015 by Travis D Gearhart



### United States Department of Transportation Docket Management System

PIC Pilot In Command SO UAs Unmanned Aircraft(s) FAA UASs Unmanned Aircraft System(s) GCS VLOS Visual Line of Sight GPS Safety Observer Federal Aviation Administration Ground Control Station Global Positioning System

Travis D Gearhart seeks exemption from the requirements of 14 C.F.R 91.7(a), 91.151(b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Travis D Gearhart to operate an Unmanned Aircraft System (UASs) without an airworthiness certification for the commercial purpose of conducting aerial video and photography including but not limited to real estate, farmland, and landscape over certain areas of the United States.

Additional Regulations from which the exemption is requested:

14 CFR Part 21 subpart H The UAS(s) to be operated carries neither pilot nor passenger and carries no explosive materials or flammable liquids. Given the size, weight, speed and limited operating area associated with the UAs and its operation, Travis D Gearhart's operation of the UAs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate.

14 CFR 61 Considering the UAs will not require an airworthiness certificate and considering the speed, weight, size, and limited operating area associated with the UAs and its operation, Travis D Gearhart requests exemption from obtaining a airline transport, commercial, private, recreational, or sport pilot certificate. By following the safety guidelines set forth by the manufacture and the additional requirements of an approved exemption Travis D Gearhart will maintain a safe environment.

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) These sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Travis D Gearhart submits that the requested relief is proper since an equivalent level of safety will be ensured. Travis D Gearhart will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents.

14 CFR 45.23 (b) Due to the size of this UAS(s)it does not have a cockpit, cabin, or pilot station on which to mark certain words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions would need to be smaller than required 2" minimum.

14 CFR 91.9 (b) (2) & 14 CFR 91.203 (a) and (b) Given the size and configuration, the UAS has no ability to carry operating documents on the aircraft. There is no room, capacity, or pilot on board to adequately carry the operating documents. A equivalent level of safety will be maintained by keeping the operating documents at ground control point where the PIC will have immediate access to it.

Page 1 of 3Submitted On-line www.regulations.gov on August 19, 2015 by Travis D Gearhart

14 CFR 91.103 As FAA approved flight manuals will not be provided for the aircraft an exemption is requested. Normal procedures including but not limited to: reviewing weather, inspecting flight area, flight battery requirement, landing and takeoff distances. An equivalent level of safety will be provided by preflight guidelines.

14 CFR 91.121 Altitude information of the UAs will be provided to the PIC via Global Positioning System (GPS) equipment and communications telemetry data link, which down-links from the UAs to the GCS for active monitoring of the flight path. This altitude information, combined with Travis D Gearhart's operation of the UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety.

14 CFR 91.151 (b) The UAs listed below are battery-powered and do not require fuel.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) Given these sections only apply to aircraft with an airworthiness certificate, these section do not apply to the applicant. As a safety precaution, PIC will perform preflight inspections and ensure the UAs is/are in working condition before initiating each flight.

Additional Beneficial Information The Public Will Benefit From Decreased Congestion Of The NAS. UAs are battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the number of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a UAS would reduce the number of manned aircraft in the NAS and reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. With the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating UAs, companies can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the UAs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

Page 2 of 3Submitted On-line www.regulations.gov on August 19, 2015 by Travis D Gearhart



### Additional Safety Information

PIC and UAs listed below will maintain a level of safety when considering the following: UAs will only be operated during daylight hours. UAs will not exceed 40 knots. UAs will only be operated below 400 feet above ground level (AGL). UAs will be operated within visual line of sight (VLOS) of the PIC at all times. UAs operating documents will available and accessible during operations. Weather conditions will be good to moderate, to avoid collisions of any kind. Flight area including ground and NAS will be inspected for hazards before each flight. UAs will undergo a manufacture Pre-Flight checklist before each flight. PIC will follow the manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. PIC Travis D Gearhart born in 1975 holds a current Colorado Drivers license. UAs complies with part 15 of FCC Rules. Operation is subject to the following two conditions: (1) this device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. UAs will not operate within 5 nautical miles of an airport reference point, unless a letter of agreement is obtained from the airport management. Both UAs listed have "Return to Home" safety features in case of loss of communication.

Thank you for taking the time to review my request.



### ~ Travis D Gearh PO Box 94 Ignacio, CO 81 / Listed UAs for exemption request. Parrot Bebop DJI Phantom 3

Documents included with this request. Parrot Bebop Bebop-drone_User-guide.pdf BAT—SAFETY_BEBOP—DRONE-297x218mm—EN-FR-27feb2015-3.pdf BD_BeBop—Datasheet-210x297-19nov14.pdf (Technical Specifications)

DJI Phantom 3 Phantom-3—Professional

— User—Manual_v1.4—en.pdf Phantom_3_Safety—Guidelines—Disclaimer—en.pdf

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