# PEACHTREE AERIAL PHOTOGRAPHY 607 Blackburn Lane Peachtree City, Georgia 30269

U.S. Department ofTransportation, Docket Operations West Building GroundFloor, Room w12-140 1200 NewJersey Avenue, SE., Washington, DC 20590

Greetings, Enclosed is myPetition for Exemption 14 CFR § 11.81. Please let me know ifl can assist in anyway throughout this process. Sincerely yours,

# /'~~"----~" Matt Miller Owner, Peachtree Aerial Photography (612) 251-6510 matt@pt-aerial.comPeachtree Aerial Photography c/o Matthew James Miller 607 Blackburn LN Peachtree City, GA 30269 (612) 251-6510 matt@pt-aerial.com 

## Summary I, Matthew James Miller, sole owner and sole Pilot In Command of Peachtree Aerial Photography LLC, seek the following exemptions from 14 CFR 

### § 11.81:

• 14 CFR part21, Subpart H (Airworthiness Certificates) 

### • § 91.203 (a) and (b) (Certifications required) 

### • § 45.23 (Marking ofthe aircraft) 

### • §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) (Maintenance inspections) 

### • § 61. 113 (Private Pilot Privileges and Limitations: Pilot in command)



## Petition for Exemption 14 CFR 

# § 11.81 MatthewJames Miller, sole ownerand sole Pilot In Command ofPeachtree Aerial Photography, LLC (PETITIONER) plans to operate 

### a UAS, the PHANTOM 3Advanced, which is comprised ofan unmanned aircraft (UA orPHANTOM) and

### a transportable ground station. The PHANTOM is referred to as a quad-copter with a maximum gross weight ofabout2. 82 pounds. It is equipped with fourrotors that are driven by electric motors powered bybatteries. The UA has 

### a maximum airspeed of30 k17ots. Petitionerplans to operate the UA over various areas near Peachtree City, Georgia to enhance academic community awareness and augment real estate listing videos.PETITIONER is making the following representations ofoperational enhancements which he proposes to abide by to ensure this exemption will provide 

### a level ofsafetyatleast equal to existing rules:

• He wi/1 only operate in reasonably safe environments that are strictly controlled, are away from powerlines, elevatedlights, airports and activelypopulated areas; and

• He wi/1 conduct extensive preflightinspections andprotocols, during which safety carries primary importance. The PETITIONER states thatgiven the size, weight, speed, and limited operating area associated with the aircraft to be utilized byhim, an exemption from 14 CFR part21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain conditions andlimitations, is warranted andmeets the requirements foran equivalent level ofsafety under 14 CFR part 11 and Section 333 of

### P.L. 112-95 (Section 333). PETITIONER requests an exemption from § 45.23 Marking ofthe aircraft because his UA will not have 

### a cabin, cockpit orpilot station on which to mark certain words orphrases. Further, he states that two-inch lettering is difficult to place on such 

### a small aircraft with dimensions smaller than the minima/lettering requirement. 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 maybe required and shouldbe granted since they onlyapply to aircraft with an airworthiness certificate. However, the petitionerstates as 

### a safety precaution he willperform 

### a preflight inspection ofhis UAS before each flight as outlined in his operating documents. The PETITIONER asserts that under§ 61.113 (a) and (b) private pilots are limited to non commercial operations, howeverhe can achieve an equivalent level ofsafety as achieved by current regulations because his UAS does not carryanypilots orpassengers. Further, he states that, while helpful, 

### a pilot license will not ensure remote controlpiloting skills. He furtherindicates that the risks ofoperating 

### a UAS are farless than the risk levels inherent in the commercial activities 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 PETITIONER states he has flown over200 hours of practice flights in remote areas as 

### a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics ofhis UAS'performance underdifferent temperature and weatherconditions. He furtherstates that he practices computerized simulated flights to maintain adequate skills and response reflex time. In 

### a supplemental request to the FAA, the petitionerrequests consideration ofa 120 day temporary airman certificate in accordance with § 63. 13, to allow him time to obtain 

### a private pilot certificate orto allow the FAA time to establish minimum UAS airman certification standards. I hereby verify that all information on this exemption request is true and correct.

Matthew Jam s Miller, sole ownerand sole Pilot In Command, Peachtree Aerial Photography LLC ' I 

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