8/28/2015

Matthew Palmquist, Owner

Camano Aerials

420 Islandcrest Dr. 

Camano Island, WA 98282

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, 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 Reform Act of 2012 ("FMRA"),

49 U.S.C. § 44701, and 14 C.F.R. Part 11, Camano Aerials hereby petitions for exemption in order to 

operate certain small unmanned aircraft systems ("sUAS") as described in this petition. Camano 

Aerials desires to conduct aerial photography, 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 within 14 C.F.R. 11, Camano Aerials, and the 

operator of the sUAS, will be operating the following 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 Section 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 if 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 great danger 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 magnitude over current conventional means.

Inspections of various buildings and structures is another public benefit using UAS’s. Workers are 

required to wear safety gear when climbing to inspect various buildings and structures. This job 

creates has a high risk 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 why the exemption would 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 333(c) of the Reform Act.

Camano Aerials 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. All 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 PIC and VO. The ability to communicate 

verbally at all times mitigates risk and assures 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 400 feet at all times.
 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 Waiver or Authorization from the FAA air traffic 

organization prior to conducting operations in the NAS.

 PIC shall remain 5 miles 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 awareness.

 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 observer 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 visibility 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 operation and control of the UA will comply with the 

Federal Communications Commission (FCC) or other appropriate government oversight 

agency requirements.

 Repair procedures for inoperative or damaged parts are replaced with guidance from the 

manufactures repair manual. Mechanical integrity and full functionality testing of the system 

will be conducted prior to any flight operation.

Minimum experience requirements for PIC UAS 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 needed 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-way radio 

communications if necessary. Normal and emergency procedures will be discussed with the VO. 

Visual Observer is in place and audibly verifies that the 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 remedied to the 

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 UAS 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 parts will be from the manufactures manual 

http://3drobotics.com/wp-content/uploads/2013/08/Y6-DIY-Assembly-Instructions-WEB.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 on 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 motors 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 prescribes that no person may operate a civil aircraft unless it is in an airworthy 

condition. 

Camano Aerials is requesting 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 500 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 

impossible. Our safety procedures outlined in the operation manual guarantee or exceed the 

equivalent level of safety 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 VFR 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 

percentage 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 achieved 

by the PIC due to the size of the UAS, the small payload it will carry and the restricted area it will 

operate. The PIC will inspect and ensure that the UAS is in a condition for safe flight in accordance 

with the operating documents. The PIC will perform general maintenance procedures or replacement 

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