September 24 , 2015

United States Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE West Building Ground Floor Room W12

- 140 Washington, DC 20590
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:
I am writing pursuant to the FAA Modernization and Reform Act (the "Reform Act") and the procedures contained in 14 C.F.R. 11, to request that Nicholas Price, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listed below so that Nicholas Price, may operate his small unmanned aircraft/ lightweight unmanned aircraft sy stems ("UAS") commerciall y in airspace regulated b y the Federal Aviation Administration ("FAA"); as long as such operations are conducted within and under the conditions outlined herein or as may be established by

the FAA as required by

Section 333.
Mr. Price has been a member of the public safety community for over sixteen ye ars, and has held a number of vital rol es in the community . Being a first responder, Mr. Price has proven how responsible he is and that safety of everyone is a high pri ority
. Mr. Price is currentl y seeking a business license that will allow himself, and only himself to provide UAS’s commercial ly

in his community

. Nicholas Price respectfully requests the grant of an exemption allowing him to operate lightweight, remote control led UAS's. The specific s ections of Title 14 of the Code of Federal Regulations are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 C FR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a)(1); 14 CFR 409 (a)(2); and, 14 CFR 417 (a) & (b). Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b) ; 14 CFR Part 21 ; 14 CFR 61.113 (a) & (b); 91.7 (a) ; 91.9 (b)(2) ; 91.103 (b); 91.109 ; 91.119 ; 91.121; 91.151(a) ; 91.203 (a) & (b) ; 91.405 (a); 91.407(a) (1); 91.409 (a) (2) ; 91.417 (a) & (b). Mr. Price’s UAS ’ s utilizes four counter

- rotating propellers for extreme balance, control and stability . They

each weigh less than 55 pound s, including cinematic or other equipment. Each unmanned aircraft are designed to primarily hover in place and operate at less than a 50

- knot maximum speed. They are capable of vertical and horizontal operations but operate only within the line of sight of the remote control pilot.Utilizing battery power and not combustible fuels, flights generall y last between five and twenty minutes. Mr. Price does not operate his UAS ’ s with less than twenty five percent battery capacity. Safety s ys tems in place include a GPS mode that allows UASs to hover in place if communication with the radio control pilot is lost and then slowly descend the UAS at twenty

five percent battery

capacity. Further, the UAS is programmed, in some instances, to slowly

follow a predetermined set of way points to return to a safety point if communications are lost. Mr. Price does not operate his UAS ’ s near airports and generally does not op erate them near populated areas

. Mr. Price only operates his UAS ’ s in predetermined areas. The FAA has the authority to issue the exemption to Nicholas Price, pursuant to the Federal Aviation Act, 85 P.L . 726 (1958), as amended (the "Act"). Below are several reasons Why Mr. Price’s exemption will not adversely affect safety: • UASs weigh less than 55 pounds complete with high definition quality cameras like the DJI12 megapixel photo camera with an integrated 3

- axis stabilization gimbal ; • Only operates UAS ’ s below 400 feet; • UAS ’ s only

operate for 5

- 25 minutes per flight; • Lands UASs when they reach 25% battery power; • Remote control pilot ing UAS ’ s by line of sight; • High definition remote control video backup should I somehow lose sight of the UAS; • UAS ’ s have GPS flight modes where they land if communication with the remote control pilot is lost or battery power is below 25% (auto

- return, auto

- land) ; • Only operates in secured areas that are strictly controlled, are away

from airports , restricted airspace and populated areas; • A lway s obtains al l necessary permissions and permits prior to operation and has procedures in place to abort flights in the event of safety breaches or potential danger.
UAS ’ s carry

no people on board and Mr. Price usually operates them in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatl y diminished. The small size and extreme maneuverab ility

of UAS ’s allow the remote control pilots to avoid hazards. A summary

the FAA may

publish in the federal r egister: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Ce rtificates

. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for Procurement of necessary airworthiness certificates in relation to FAR § 91.203(a) (l). The size, weight and enclosed operational area of Mr. Price’s UAS ’ s permits exemption from Part 21 because the UASs meet an equivalent level of safety pursuant to Section 33 3 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation pe rmit the FAA to exempt UAS ’ s from the airworthiness certificate requirement in consideration of the weight, size, spee d, maneuverability

and proximity

to areas such as airports and dense populations. Mr. Price’s UAS ’ 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 contemplated by the F ARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UASs, this Regulation is inapplicable. The FAA has previousl y issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable as Mr. Price’s UAS ’ s utilize electronic global positioning sy stems and internal gy roscopes to provide spatial coordination. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same re asons described above. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. UASs are, by def in ition, unmanned. They

therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft. Regardless, Mr. Price will mark its UASs in the largest possible lettering required b y 14 C.F.R. §45.29 (f) if an exemption i s not granted so that the pilot and others working near the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 14 C.F.R. § 61.113: Private Pilot Privileges and Limi tations: PI C. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I can achieve an equivalent level of safety as achieved by current regulations because UAS ’ s do not carry any pilots or passengers. 14 C.F.R . 91.119: 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 altitudes in certain conditions. UAS ’ s will never operate at an altitude greater than 400 ft

. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These Regulations only

apply to aircraft with an airworthiness certificate. They will not, therefore, appl y to Nicholas Price should my requested exemption be granted. Mr. Price conducts an extensive maintenance program that involves regular software updates and constant inspection for assessment of any damaged hardware. Therefore, an equivalent le vel of safety

will be achieved.Summary

Nicholas Price seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.P.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. § 91.407 (a)(1); 14 C.P.R. § 91.409 (a)(2); 14 C.P.R. § 91.409 (a)(2); and, 14 C.P.R. §§ 91.417 (a) & (b) to commerciall y operate his fleet of small unmanned vehicle s and lightweight unmanned aircraft

. There are no people on board the UAS ’ s and therefore the likelihood of death or serious bodily injury is significantl y limited. Nicholas Price’s operation of his UAS ’ s, weighting less than 55 pounds and traveling at sp eeds lower than 50 knots in contained areas will provide at least an equivalent level of safety a s that achieved under current F ARs. Nicholas Price respectfully requests that the FAA grant its exemption request without delay . The FAA has the authority to issue the exemption sought by Nicholas Price pursuant to the Federal Aviation Act, 85 P.L . 726 (1958), as amended (the "Act"). Sincerel y, Nicholas Price 127 E. 5 th Avenue Escondido, CA 92025 Nprice1127@aol.com