### July 28
, 2015

Exemption No. 12211 Regulatory Docket No. FAA

–20 15

– 1910

Mr. William B. Adams 1105 Addington Drive Commerce T ownshi p, MI 48390

Dear Mr. Adams :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
By letter dated May 13, 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography and inspection

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.
Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3

. The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

### 2

14 CFR part 21
, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision
You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater propo rtions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.
Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you pre sent; and

 A grant of exemption is in the public interest.

Our Decision
In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. William B. Adams is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. William B. Adams is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemp tion

.
2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no mor e than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than

co rrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;
e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and con duct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the o perator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrat or or any law enforcement official upon request. The

### 4

operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the b asis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating docum ents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.
, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other p eople. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.
, inoperable components, items, or equipment. If the i nspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, v essels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

### 5

(traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance w ith 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The U A may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published a eronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or an y law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre

- determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be con ducted under the terms of the attached COA

.
22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control St ation of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present th at sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such p rotection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer t o those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.
The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documente d in this grant of exemption.

### 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of propos ed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted und er this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement th at the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or repres entative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS oper ations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8

This exemption terminates on July 31, 2017 , unless sooner superseded or rescinded.
Sincerely,

/s/ John S. Duncan Director, Flight Standards Service

EnclosuresWilliam Adams, Comme r ce T wp, MI Section

- 333 Exemption Petition

May 13,2015 

### William B. Adams 1105 Addington Drive Commerce Twp.
, MI 48390 William-Adams@comcast.net (248) 330-0836

U. S. Department of Tran sportat ion Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

R e: Exemption**R~uest** Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C. F .R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 9 1 .103(b); 91.109; ll9.121; 91.1SI(a); 91.203(a)&(b); 91.405(a); 91.407(•) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

William Adams hereby petitiOns the Secretary of Transportation and Federal Aviation Administration for exemption to the above referenced and below more fully described Federal Aviation Regulations ("FARs"), that currently may or may not apply to the recreational/business operations of model aircraft including small unmarmed aerial systems ("UASs).

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. II, Petition that I, William Adams, an owner and operator of small unmarmed aircraft, be exempted from the Federal Aviation Regulations ("F ARs") listed below so that 1, William Adams, may operate my small ultra lightweight unmanned aircraft system ("UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA").

As described herein I, William Adams, am a licensed Private Pilot (Certificate #38 1569777) ; Experienced in flying hobby helicopters and fixed wing aircraft for recreational purposes for

over 25 years. I have added a hobby grade OJ! Phantom 3 quadcopter UAS to my inventory with intent to conduct aerial photography/Inspection! included but not limited to the following; Business Operations: over land, waterways, and oceans; Operation over / in non-restricted National Parks, National Forests, flight in non-navigable airspace, using nonintrusive recording devices, operation in othenvise unrestricted U.S. Statesfferritories for aerial videography / cinematography for commercial operation and to enhance academic community

awareness for those individuals and companies unfamiliar with the geographical layout of such

areas.

As described more fully below, the requested exemption would permit the operation of UAS under controlled conditions in airspace that is I) limited; 2) predetennined in areas away from general public, airports, heliports and vehicular traffic for community videos, and within property boundaries for individual homeowner real estate listing videos/photos; and 3) controlled

as to access. The exemption would also provide safety enhancements to the already safeWilli a m Ad a m s, Co mm e r ce Tw p , M l Secti o n- 333 Ex empti o n P e tition

operations within the aerial photography, film and television industry presently using conventional aircraft and small, unmanned and relative ly inexpensive VASs.

Currently, similar lightweight, remote controlled VAS's are legally operated by urunonitored
amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I operate my UAS within al l safety protocols and contro l s 1 to avo id and prevent public hazard, as well as ma•med aircraft hazards/catastrophe

. This will act to further safety protocols exclusive to lightweight VAS's specific to aerial video and photography usage as I record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to assist with future protocol and safety regulation.

Grant ing my request comports with the Secretary of Transportation's (FAA Administrator's)

r esponsibilities and authority to not only integrate VAS's into the national airspace system, but to "

... establish requirements for the safe operation of such aircraft systems [VAS's] in the national airspace system" under Section 333(c) of the Reform Act specific to the use of VAS's for commercia l purposes. Further I will conduct my operations in comp liance with the protoco l s described herein or as otherwise establ i shed by the FAA.

For the reasons stated below I respectfully request the grant of an exemption allowing me t o opera t e ultra lightweight, remote controlled VAS's for academic community awareness, benefit/stimu late tourism within Michigan, general aeria l photography, and to enhance real estate li sting videos for h omeowners who cannot afford expensive manned aircraft for the same p urpose, all of which will p romote local economic growth through increased employment and increased t ax base. Both with public safety in mind by keeping heavier manned aircraft containing combustib l e fuel that that poses potentia l publ ic hazard.

I. Contact Information:

William Adams I I 05 Addington Drive Commerce Twp., Ml48390 Mobile: (248) 330-0836 Emai l : William-Adams@comcast.net



### ll. T h e S p e cific S e c ti o n s of Titl e 14 of the C od e of F e d e ral Re g ulation s From Which William Adam s R e qu es t s Exe mption ar e:

! 4CFR21; 1 4 C.F.R. 45

. 23(b); 1 4 CFR 61.1 J3 (a) & (b): 14 C.F.R. 91.7 (a); 1 4 C

. F

. R. 91.9 (b) (2); 1 4 C.F.R. 91.103: 1 4 C

. F

. R. 91.109: 1 4 C.F.R. 91.119; 1 4 C.F.R. 91.121; 14 C.F.R. 91.151 (a);

1 Safecy Protocols & Controls Phantom 3 Usee Manual in addirion co Minimum VFR regulationsWilliam Adams, Comme r ce T w p , M l Sec tion

- 333 Exemption P e ti tion

1 4 C.F.R. 9 1 .203 (a) & (b); 14 C.F.R. 91.405 (a); 1 4 CFR 407 (a)( I); 14 CFR 409 (a) (2); and, 14CFR417(a)&(b).

III

. The Extent o f reli e f William Adam s seeks and th e R eason H e Seeks S u c h R elief:

I, William Adams, submit this app l ication in accordance with the Reform Act, 112 P.L. 95 

### §§ 33 1 334, seeking relief from any currently applicab le FARs operating to prevent
me, William Adams, contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system

as it is in the public's interest to do so. My ultra light weight UAS meets the definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of my

u ltra l ight weight UAS i s expressly contemp l ated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UASs that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; \1/hether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of s ight. 112 P.L. 95 

### § 333 (a). Each of these items reflect in favor of an exemption for me, William Adams. My UAS utilizes four (4)
counter

- rotating propellers for balance, control and stability. My UAS is equipped with GPS, obstacle avoidance sensors and auto return safety technology

. Weighing less than

seven (7) pounds (far below the maximum 55 pound limit); including camera with gimbal.

I consider safety as foremost with each flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a II m/s wind knot (approx 23 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 7 mls (15 mph). Built in safety systems include a GPS mode that allows my UAS to hover in p l ace when radio controls are lost. With three modes to choose from, I utilize the 

### Positioning Modi for aerial videography / photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pi lot communication is lost UAS is designed slowly descend to point of takeoff, or near the control transmitter when utilizing Dynamic Mode. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is \vithin fifty to one hundred (50-1 00) yards depending on location, conditions and weather. I am constantly

on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point shoul d a manned aircraft approach my location or I suspect manned aircraft may approach near my location

. My UAS is capable of vertical and horizontal operations, and are flown only within my line

2 Positing Mode**inclt~Ms** GPS, Vision PO$itioning Sensors. and BarolllC'tcr for position hold. sclf·levcling. ahitude command. GPS. rttum home and dynamic rccum to home: feature. and safety comrol to return home or land in the event ofcommunication interruption bel\\•ee1t RC transminer and UAS

. Set' "Flight Mode" in Phamom 3 User Ma nu alWillia m Adam s, Co mm e r ce T wp , M1 Sec ti o n- 3 33 E xe mp ti on P e titi o n

of sight, as the remote control pi lot. I also use a spotter and clear the airspace we are working in.

Utilizing battery power rather than combustible fue l s, flights generally last between eight (8) to twelve (12) m inutes, with an altitude under two hundred fifty (250) feet. I uti li ze a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is eighteen ( 1 8) to twenty-two (22) minutes as tested. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potentia l for crash
, loss of control or hazard. Reserve batteries are at and with each exercise to insure rep lacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, that coul d create hazard to the public/property / manned aircraft
, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain fami liarization with the characterist ics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simul ated flights to maintain adequate skills and response reflex time. All for the sake of safety.

I am extremely cautious when operat ing of my UAS / ultra l ightweight unmanned aircraft and will not "create a hazard to users of the national airspace sys t em or the pub lic." 1 1 2 P.L. 95 

### § 333 (b). Given the small size and weight of my UAS it falls well within Congress's contemp lated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the n ational airspace system. My UAS, the DJI Phantom 3, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

IV. How William Adam s's R e que s t Will Ben e fit th e Public A s A Whol e :

Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estat e companies and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense, depriving non luxury homeowners and lowe r budget Realtors from a valuable marketing tool.

The pub lic's interest i s additionally furthered by allowing small businesses in the tourism industry to afford the current l y cost prohi bitive aeria l photography used by large internationa l corporations. With drone technology smal l bus i nesses have the opportunity to level the marketing playing field and become more compet itive b y utilizing s t ate of the
art drone cinematography. Additionally, smaller private hotels/resorts are harmed by internat ional resorts and their abil ity to market using such aerial videography drawing business outside the economic benefit of the United States

. Congress has already proclaimed that it is in the public's interest to integrate commercial ly flown UAS's into the nat ional airspace system, hence the passing of the Reform Act. Granting my exemption request furthe rs the public interest through academic/visua l awareness of the geographical benefits i n and around the State of

### William Adam s, Co mm e rce T wp , Ml Secti o n

- 333 E xe mption P etition

M ichigan. My ultra light weight UAS is battery powered and creates no emissions that

can harm the environment. The consequence of my ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devas t ation to the pub lic.

Manned aircraft can pose a threat to the public through potential catastrophic crash that many local communities have experienced in the past with military aircraft and medicaVpo lice helicopter crashes. These have resu lted in a loss of l ife and endangered the public with combustible fuel that burned on impact. My UAS poses no such threat since size and lack of combustib le fuel alleviates any potential threat to the public. Addit ionally, this actually furthers the public's interest by making it safer for business to conduct aerial photography and videography without such risks.

The p ublic's interest is furthered by minimizing ecological and crash threat by permitting aerial video/ photo capture through my battery operated ultra light weight UAS's. Permitting me to i mmedi ately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact within the Sta t e of M ichigan for companies l ooking to relocate or bu ild in Michigan as well as individuals looking to relocate for career advancement through academic and geographical awareness; both of whi ch serve as a stimulus to the community.

V. 

### R e ason s " Why Willinm Adam s's E xe mption Will Not Ad v er s el y Affect S afe ty Or 

### How Th e E xe mption Will Pro vi d e a 

### Le vel of S afe ty At 

### Len s t Equal To E xisting Rul e :
My exempt ion wi ll not adversely affect safety. Quite t he contrary, for the reasons stated pennitting me to log more flight time in FAA controlled airspace, with communication with the FAA, w i ll allow me to contribute t o the innovat i on and implementat i on of new and novel
, as of yet undiscovered safety p r otocols fo r development in cooperation w ith the FAA

. In addition I submit the following representations of enhancements to current aerial videography and photography:

A. My UAS weighs less than 7 pounds comp lete with a small u ltra light weight high quality camera; B. I only operate my UAS be low 300 fee t (well within the 400 foot permissible cei l ing set by the FAA Modernization and R eform Ac t of2012); C

. My UAS only opera t es for 18- 22 minutes per flight; D. I land my UAS prior to 20% Battery R emaining; E

. I pilot my UAS through remote control on ly by line of sight; F. I pilot my UAS only with a visual observer; G. My UAS has Failsafe RTH, a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot i s lost for 3 seconds; H. My UAS has GPS and a Vision Pos itioning System utilizing two sonar sensors and one monocula r camera for positioning and to identify the current aircraft's posi t ion; I. My UAS has a flight recorder and I actively analyze flight data and other sources of informat ion to constantly update and enhance safety p r otocols;Willi a m A d am s, Commer ce T w p , M1 Sec ti o n

- 3 33 Exempti o n P e ti tio n

J. l only operate in reasonably safe environment that are strictly controlled
, are away from power lines, elevated lights, airports and active ly popul ated ar eas; 

### K

. I conduct extensive preflight inspections and protocol per the Phantom 

### 3 User Manua l ; L. I always obtain all necessary permissions prior to operation; M

. I immediately abort flights in the event of potentia l danger ; 

### N. I only operate my UAS well within "flight environment requirements 4 " & visual meteorologica l conditions (VMC). 

### 0. I will not operate my UAS less than 

### 500 feet below or less than 

### 2
, 000 fee t horizontally from a cloud or when visibility is less than 3 statute m iles from the PIC. P. Only I
, William Adams
, a l icensed Private Pilot (Certificate # 381569777, act 

## as Pi lot i n Command during flights; Q

. I fo ll ow the UAS manufacturer's aircraft/component
, maintenance; overhau l
, replacement, inspection, and life limit requirements. R. The operating documents/manual will be accessible during UAS operations and made available upon r equest. S

. My UAS has a vision detection system that allows it to land automatically even when GPS signal is lost U. I will be carrying 

### $1,000,000 CSL Property and Liability commerc i a l insurance

My safety protoco l s 5 provide a leve l of safety equal to or e x ceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aeria l video and photography for community awareness , real estate , and marketing purposes. While the safety record of such helicopters is remarkab ly astounding, ther e have been incidents involving loss of life as we ll as exten s ive property damage; it is far safer to operate a battery powered ultra light we ight UAS.

• First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS i n specific areas away from mass populations

. • Second, there i s no fuel on board a VAS and thus the potential for fire or explosions is greatly diminished.

• Third
, the small size and extreme maneuverab i lity of my UAS al low me to remote ly pilot away from and avoid hazards quic kly and safely

. • Fourth
, given its small s i ze and weight
, even when close enough to capture amazing images, my VAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom.
According l y, my UAS has been experimentally operated for fami liarization and competency and will continue to operate at and above cunent safety levels.

VI

. A S ummary The FAA Ma y Publi s h in th e Federa l R e gi s t e r:

A

. 1 4 C.F.R. 21 and 14 C.F.R. 91 : Airworthiness Certificates, Manuals and The Like.



## ' Ai"'**l:a\~ 1**  Rcqulmocw' · "**t' -IS- "'-nnocn3 Utcr Maftllal
S**~lclj** wlt!tlti fbJ!w: Ltrnitttiu. .t f'roctdurd out lllled in UMS M111111.1l A·R liMed lbo-o"t'

. 'reUII roet4'01'01opntlC:o.tiiiOm {Or VMC). k .-y t\nlbtllbk fAllsWiiJiam Adam s, Comme r ce Twp
, MI Section

- 333 Exemption P e tition

14 C.F. R

. 21, Subpart H
, entitle:<! Airworthiness Certificates, sets forth r equirements for procurement of necessary air.vorthiness certificates in relation to FAR 

### § 91.203(a)(l). The size, weight and enclosed operational area of my VAS permits exemption from P art 21 because my

VAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA i s authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 V.S.C. 

### § 44701 (t)) and Section 333 of the Refom1 Act. Both pieces of legislation permit the FAA to exempt VAS's from the air.vorthiness certificate requ irement in consideration of the weight, size, speed, maneuverability and proxim ity to areas such as airports and dense populations. My current and projected VAS's meet or exceed each of the elements

.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemp lated by the FARs, this Regulation is inapp licable.

1 4 C.F.R. 

### § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are

no on board pilots or passengers, and given the size of the VAS's, this Regulation is inapp licable. An equ ivalent level of safety will be achieved by maintaining a safety/fl ight manual de lineating areas of where safety can be defined. I 0 The FAA has previously issued exemptions to this regulation in Exemption Nos

. 8607, 873 7, 8738,9299, 9299A, 9565,95658, 10167
, 10 1 67A, 10602, 10700 and 32827.

14 C.F .R

. 

### § 91.121 regarding altimeter settings is inapplicable in so far as my VAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civi l aircraft certifications and registration s

. They are i napplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, William Adan1s.

B

. 14 C.F.R. 

### § 45.23: Marking ofThe A ir craft

App licable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My VAS are, by definition, wlffianned.

They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phra ses

. Further, two inch lettering is difficult to place on such small aircraft with dinlensions smaller that minimal lettering requirement. The FAA has previously issued exemptions to this regu l ation through Exemptions Nos. 8738
, 10167, 10167A and 10700.

C. 14 C.F .R . § 61.113: Private Pilot Privileges and Limitations: PIC.William Adam s, Commerce Twp
, MI Section

- 333 Exemption Petition

Pursuant to 14 C.F.R. 

### §§ 61.113 (a) & (b)
, private pilots are limited to noncommercial operations. I, William Adams, can achieve an equivalent l evel of safety as achieved by current Regulations because my UAS does not carry any pilots

or passengers. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. 

### § 61, et seq. Thus, allowing me to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). In addition, Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground.

D. 14 C

. F.R. 9 1 .119: Minimum Safe Altitudes.

14 C.F.R. 

### § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower alt itudes in certain conditions. My UAS will never operate at an al titude greater than 300 AGL; safely below the standard of 400 AGL. I will however operate my UAS in safe areas away from public and traffic
, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size
, weight, maneuverabi lity and speed of my UAS
, an equivalent or higher level of safety will be achieved.

E

. 14 C.F.R

. 91.405 (a); 407 (a) (I); 409 (a) (2); 4 1 7(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other thing s, aircraft owners and operators to ' 'have [the] aircraft inspected as prescribed in subpart E of this part and shall berween required inspections
, except as provided in paragraph (c) of this section. have discrepancies repaired as preseribed in pan 43 of this chapter

...."

These Regulati ons only apply to aircraft with an airworthiness certificate.

They will not, therefore, apply to my UAS. However, as a safety precaution I inspect my UAS before and after each flight and ma intained per the manufacturer's aircraft / component, maintenance, overhaul, replacement, inspection, and life limit requirements.

I n summary, William Ada m s s eek s a n exemption fro m t h e f ollowing Reg ul ations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. 

### § 91.9 (b)(2); 14 C.F.R. 

### § 91.103(b); 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) and (b); 14 C.F.R. 

### § 91.405 (a); 14 C.F.R. 

### § 9 1.407 (a)(l); 14 C.F

. R

. 

### § 91.409 (a)(2): 14 C.F.R

. § 91.409 (a) (2); and, 14 C.F

. R. §§ 91.417 (a) & (b) to conunercia ll y operate my lightweight unmanned aircraft system for aerial photography / Inspection/included but not limited to the following; Business Operations: over l and, waterways, and oceans ; operation over / in nonrestricted Nationa l Parks
, National Forests, flight in notmavigable airspace, using nonintrusive recording devices, operation in otherwise unrestricted U.S. States/Territories for aerial videography / cinematography for commercial operation and to enhanceWilliam A dam s, Co mmerc e Twp, Mr Sec tion

- 333 Exemption Petition

academic community awareness for those individuals and companies unfamiliar with the geographical layout of such areas. Currently, area awareness and real estate aerial videography / photography relies primarily on the use of larger aircraft running on combustible fuel, posing potential risk to the public. Granting my request for exemption will reduce current risk levels and thereby enhance safety. My UAS does
not contain potentially explosive fuel, is smaller
, lighter and more maneuverable than conventional photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airfields. I have been analyzing flight information and will compile safety protocols and the implementation of a flight operations manual that exceeds currently accepted means and methods for safe flight. Fonnal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of2012. There

are no personnel on board my UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. The operation of my UAS, weighing less than 7 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current F ARs. Accordingly I respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing infom1ation to benefit tile FAA, safety of manned aircraft, and the general public at large.

i William Adams