8/28/2015 Matt hew Palmquist, Owner Camano Aerials 420 Islandcrest Dr. Camano Island, WA 98282 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Wa shington, DC 20590 Dear Sir or Madam, RE: Exemption Request Section 333 of the FAA Reform Act Attachments :

 3DR Y6 Operating Manual Volume 1
 3DR Y6 Operating Manual Volume 2
 Additional Operator Guide
Camano Aerials is requesting an exemption from the following regulations as well as other pertinent regulations that apply to the operation of unmanned aerial systems (UAS). Part 21 ; 14 C.F.R. 91.7(a); 91.119(c); 119.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) & (b) Pursuant to Section 333 of the FAA Modernization and Refo rm Act of 2012 ("FMRA"), 49 U.S.C. § 44701, and 14 C.F.R. Part 11, Camano Aerial s hereby petitions for exemption in order to operate certain small unmanned aircraft systems ("sUAS") as described in this petition. Camano Aerial s desires to conduct aerial p h otography , survey and inspection for various industries that provides the service in a safe , faster and more cost effective manner. The proposed limitations and conditions on sUAS operations described in the operating manual would ensure safe flight and would result from compliance with the specific (FAR’S) from which exemption is sought. The petitioner understands the requirement for FAA approval for commercial operations. As an airline pilot for a major carrier, my knowledge of the national airspace system and maintenance requirements for aircraft for safe flight would ensure an equivalent level of safety. Pursuant to Section 333 and the procedures contained wit hin 14 C.F.R. 11, Camano Aerials, and the operator of the sUAS, will be operating the foll owing sUAS system commercially in airspace regulated by the FAA. :

 3DR Y6 with Gimbal and GoPro Camera or small point and shoot camera

.**Public Benefit** Granting this Sect ion 333 Exemption would have a positive impact on the public as a whole in the following ways: The carbon footprint is reduced tremendously to lessen the environmental impact . Current means for aerial photography, survey and inspection require large helicopters or airplanes carrying hundreds of gallons of fuel to conduct the work. The 3DR Y6 can carry out the same objective using rechargeable batteries. Noise pollution is another problem facing low fling aircraft and helicopters. The general public with benefit from the near silent operation of the 3DR Y6 to reduce i f not eliminate noise and less likely to disturb neighboring property owners. Current practices to take aerial photos/video and survey is dangerous in that the operator of an aircraft must fly at low altitudes to achieve the objective. This can pose a grea t dan ger to life and property if there is a mechanical emergency with the aircraft. An engine failure would force the operator to land the aircraft with seconds to spare. Operating the UAS will reduce risk to life, limb and property damage in orders of magnit ude over current conventional means. I nspections of various buildings and structures is another public benefit using UAS’s. W orkers are required to wear safety gear when climbing to inspect various buildings and structures . This job creates has a high ri sk of injury or death. The 3DR Y6 would not involve personnel in such activities and would complete the work with an unmanned aircraft which poses little to zero risk for life safety.

**Reasons w hy** 

**the exemption w ould not adversely affect safety**  Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator s) responsibilities to "...establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 33 3(c) of the Reform Act. Camano Aerial s will strive to make aerial operations safe. Below are the safety and operational rules we will follow under section 333.

 Because the applicant currently holds a FAA Airline Transport Pilot Certificate (ATP), the applicant has a high regard to safe operations, as well as a necessary high

- level understanding of the NAS and FARs. The FAA ATP certificate adds significantly to the level of safety in any operation performed by the applicant or the applicant's employees.
 Our PIC credentials and currency requirements along with detailed operating procedures and checklists are to assure the level of competency required for safe and successful flight operations.
 The UAS applicant will be fully trained for the UAS flight. Al l normal as well as abnormal/emergency operations will be trained to proficiency. Training will also include all normal maneuvers for the operations requested in the exemption.
 VLOS operations will always be conducted by the PI C and VO . The ability to communicate verbally at all times mitigates risk and assu res operational control of the UAS at all times. The VO will be briefed on the safety and rules of the operation.
 The failsafe functionality and a 6 motor design is able to withstand a single motor out scenario for redundancy. Return to home/launch point and safe landing capability under failure scenarios further mitigates mishaps and assures full operational control to prevent injury and damage. This solves the loss of link issues that others are concerned about.
 The UAS will operate in a designated predetermined area below 4 00 feet at all time s
. The UAS will remain clear of and yield the right of way to all other aviation operations and

activities at all times.
 PIC will avoid operations over populated areas and stay within the “sterile area ”. PIC shall remain 500 feet from non

- participating subjects

.  PIC will conduct operations in Class G airspace . Any operation in the national airspace system shall obtain a (COA) Certificate of Wa iver or Authorization from the FAA air traffic organization prior to conducting operations in the NAS.
 PIC shall remain 5 mi les from any airport. If operations require flight within 5 miles of an airport, the PIC will contact the airport and control tower before flying. **VFR Sectional charts** shall be used in either a paper or electronic form for situational awarene ss.  The PIC will not fly around people or stadiums and shall not fly in a careless or reckless manner with our unmanned aircraft
 Our aircraft will not weigh more than 55lbs

.  Flights occurring over private or controlled
- access property will get permission from the landowner. Any images taken will be of individuals who have consented to be filmed or otherwise have agreed to be in the area where aerial photography will take place. In addition, all flights will be monitored by the operator and a visual observe r to ensure that the sUAS does not deviate from the proposed flight plan.
 UAS operations may not be conducted during night. All operations will be conducted under visual meteorological conditions (VMC). Under no circumstances will we operate under special visual flight rules (SVFR).
 The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibil ity is less than 3 statute miles

.  The UAS will not be operated by the PIC from any moving device or vehicle.
 The radio frequency spectrum used for opera tion and control of the UA will comply with the Federal Communications Commissi on (FCC) or other appropriate government oversight agency requirements.
 Repair procedures for inoperative or damaged parts are replaced with guidance from the manufactures repair manual. M echanical integrity and full functionality testing of the system wi ll be conducted prior to any flight operation.
**Minimum experience requirements for PIC UA S commercial operations.** 

 PIC must, at a minimum, hold a commercial pilot certificate and a second class medical certificate
 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with similar UAS type (single blade or multicopter).
 PIC must have accumulated a minimum of 5 hours as UAS pilot operating the make and model of UAS to be utilized for operations.
 Must have three take
-offs and landings in the proceeding 90 days.
**Preflight procedures to ensure safe operation** The preflight checks will be accomplished before any operation of the UAS. The preflight checklist along with the operations rules and limitations will be reviewed before any UAS operation. A fight log will be present to log the successful completion of the pre

-flight checks. This document will be presented if need ed to any FAA official on site.**Visual Observer duties ( VO )** The visual observer is required primarily to alarm the PIC of any dangers to people or property. Detailed altitude and distance limits will be discussed and double checked by the VO as well to mitigate any issues or conflict. Communications will be verbal in nature and will provide 2

-wa y radio communications if necessary. Normal and emergency procedures will be discussed with the VO. Visual Observer is in place and audibly verifies that th e area is clear to proceed with the flight mission.
**Maintenance procedures for the 3DR Y6**
Prior to every flight, the PIC will: 1. Inspect the aircraft to ensure that it is in an airworthy condition

. 2. Maintenance procedures or replacement of consumable items outlined by the sUAS manufacturer, if applicable, will be complied with by the PlC. 3. In no circumstance will a UAS be operated in a condition that is deemed, or suspected to be, unsafe. If such a determination is reached, and the problem cannot be remedi ed to th e satisfaction of the PlC, the UAS will not be operated until consulting with the manufacturer or one of its authorized dealers to complete necessary repairs. The preflight checklist covers the required necessary checks for airworthiness. If the U AS is out of airworthy status, the part will be replaced, documented in writing and flight tested as an airworthiness check. A logbook entry will be made of the flight test and then returned to service if it passes airworthiness. Guidance for repairs on p arts will be from the manufactures manual http://3drobotics.com/wp

- content/uploads/2013/08/Y6

- DIY
-Assembly
- Instructions
-WE B.pdf.” If any software repairs are necessary, the PIC shall refer the 3DR operating manual as well as a 3DR online guide at copter.ardupilot.com . All software repairs shall be recorded in the maintenance manual. Flight testing shall also be conducted and recorded in the UAS operator’s logbook. At the first sign of excessive wear o n any UAS part, it shall be replaced immediately. Although there is no guidance from the manufacturer on when to replace perfectly working parts, it is up to the PIC to determine when parts should be replaced due to wear and tear. UAS parts such as moto rs and speed controllers which wear the most, shall be closely monitored for abnormal operations. The 3DR Y6 has built in redundancy for UAS operations. If one motor or speed controller fails, the other motor will speed up to compensate for the loss of thrust of the inoperative motor or speed controller. The APM autopilot controls the remaining speed controller and speeds up the remaining motor to maintain altitude. The 3DR Y6 is fully controllable during this event and can be safely landed at the home base or land in its present position. Unlike other quad
- copters, the 3DR Y6 will not crash if one motor fails. Redundancy is built into the 3DR Y6 to provide a safe flight experience.**The petitioner requests relief from the following regulations: Part 21**  **; 14 C.F.R. 91.7(a)**  **; 91.119**  **(c) ;**  **119.121 ; 91.151(a);**  **91.405(a) ; 91.407(a)(1);**  **91.409(a)(2) ;**  **91.417(a) & (b)**
91.7(a) Civil aircraft airworthiness This section p rescribes that no person may operate a civil aircraft unless it is in an airworthy condition. Camano Aerials is request ing relief from this section because it prohibits the operation of an aircraft without an airworthiness certificate. The PIC and VO will ensure that the 3DR Y6 is in full compliance with the operating procedures and limitations specified in the Operating manual. All checklist and maintenance procedures will be strictly adhered to maintain airworthiness status.

91.119 (c) Minimum safe altitudes for the operation of civil aircraft Section 91.119 (c) requires that no operation is permitted below 5 00 ft. AGL, except over open water and sparsely populated areas. Camano Aerials is requesting relief because the type of operations the 3DR Y6 will require altitudes below 500 feet. Maintaining 500 feet above persons in the operation or other objects would be im possible . Our safety procedures outlined in the operation manual guarantee or exceed the equivalent level of safe ty for the operations requested.

91.121 Altimeter settings Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” Camano Aerials is requesting relief from this section because the 3DR Y6 does not have an altimeter

. In lieu of these specific requirements, the Y6 will use the GPS altitude received from the telemetry which is displayed on a screen for the PIC. Our preflight procedures will check the launch altitude before every flight. This will satisfy the equivalent level of safety for the operations requested.
91.151 Fuel requirements for flights in VF R conditions Section 91.121 requires that no person may begin a flight under Visual Flight Rule (VFR) conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, (1) during the day, to fly after that for at least 30 minutes, or (2) at night, to fly after that for at least 45 minutes. Camano Aerials is requesting relief for this section. The 3DR Y6 provides battery power remaining in percen tage for the PIC. Information provided in the operation manual prescribes the procedures regarding remaining battery power management. The PIC shall land the UAS with a minimum 25 % battery power. The 3DR Y6 has a built in capability to monitor battery levels in real time as well as provide audible warnings upon low limit levels of battery capacity. The charge on every battery will be verified to be full before each flight. Every battery will also be inspected for damage before each flight. With the detailed battery monitoring and preflight inspections, we believe that we’ve met the equivalent level of safety.91.401
-417 Maintenance Inspections 14 CFR 91.405 (a ) Maintenance required, 91.407(a) (1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 91.409(a) (1) and (2) Inspections, and 91.417(a) and (b) Maintenance records. Camano Aerials is requesting relief of these sections. An equivalent level of safety will be a chieved by the PIC due to the size of the UAS, the small payload it will carry and the re stricted area it will operate. The PIC will inspect and ensure that the UAS is i n a condition for safe flight in accordance with the operating documents. The PIC will perform general maintenance procedures or replacem ent of items as outlined by the UA’ s manufacturer. If the PIC feels that maintenance should be performed, it will be noted in a maintenance logbook. If flight testing is needed, the flight will be noted in the flight logbook.
Sincerely,

Matthew Palmquist, Owner Camano Aerials