.- -i"• 08/18/2015
Attn: Rod Cambridge 123 St. Germain Lane Pleasant Hill CA 94523 =,._**,.~~ -~)** **r~** 925 300 5911 one_two_west@yahoo.com

TO: Federal Aviation Administration US Department ofTransportation Docket Management System 1200 NewJersey Ave. S.E Washington, DC. 20590

Re: 

### '

Exemption Request Section 333 ofthe FAA Reform Act Pursuant to section 333 ofthe FAA Modernization and Reform act of2012 (The Reform Act), and 14 C.F.R. Part 11, Rod Cambridge, herby seeks and applies for an exemption to the Federal Aviation Regulations (FARs) to allow Rod Cambridge to operate Small Unmanned Aircraft Systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) underthe conditions and limitations set forth in this petition. The requested exemption would permit Rod Cambridge to operate small, unmanned aircraft system (UAS) forthe purpose of providing an aerial photography and survey service to Municipalities, Utilities & Private consumers. The areas of use will include both photo and video in the Utilities, Communications industry, real estate industry, surveying industry, construction industry and agricultural industry. The UAS will be operated in airspace that is 1) limited 2) predetermined 3) would provide added safety enhancements to the already.safe qperatjons in the industry presently using conventional aircraft system"
Exemption request to section 333 ofthe FAA Reform Act Plan 11 Specific to UAS operations.
14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) & (b); 14 CFR 91.103;14 CFR 91.105; 14 CFR 91.109: 14 CFR 91.119(c);14 CFR 91.121; 14CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.401(a)(1):& {2); 14 CFR 91.417(a) 7 (b).

,·•

.. ,.; ,. .,

### ..Dear Sir or Madam:
Commercial operation ofan UAS, as described herein, which are equipped with camera(s} and sensors, would operate in the following manner: Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. Aerial video and/or photography offor public and/or private use including television, public events, cinematography and news gatherings. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority. Aerial inspection/photography of residential/commercial utility infrastructure included but not limited to electrical power lines, wind turbines and cell towers. Aerial video/photography or providing live video feed to assist with rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract and/or donation. The abilityto offertraining to persons or individuals belonging to both private and/or public organizations that have interests in the use and application of UAS for the purpose ofthe safe operation ofa UAS to enhance the safety of national aerospace system (NAS} as well as for protection ofthe persons and property.

As described fully below, and to be used as FOM (exibit#lL the requested exemptions would permit the operation of a UAS under controlled conditions in the NAS that would be a} limited, b) controlled, c) predetermined, and d) will provide safety enhancements such as limited exposure to flight crew, climbing crews, weight ofvehicles, speeds of usage, non use ofvolatile fuels, ect. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportations (the FAA administrators} responsibilities to "

....establish requirements for the safe operation of such aircraft systems in the national airspace system.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The primaryvehicle to be used will be the DJIInspirel and or DJI Phantom 3. While vehicles may be upgraded as newtechnological and safety advanced occurthe barfor operation and safety will be set by DJIInspire 1 and any newvehicles orversions will exceed the current safety and operational standards. No vehicle operated by Rod Cambridge will be modified from the manufacturers design unless specifically directed by the same manufacturer. The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as set forth in the flight operations manual include:

# Exhibit #1

The UAS will weigh less than 55 lbs The UAS will have a maximum operating speed of no more than 100 mph Flights will be operated within line ofsight ofthe pilot in command and/orvisual observer Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes offlight time whichever occurs first Flights will be operated at altitude of no more than 200 feet above ground level and no more than 200 feet above an equivalent platform from which filming is planned. UAS will NOT operate. 5 nautical miles (NM) from an airport having an operational control tower; or
3 NM from an airportwith a published instrumentflight procedure, but not an operational tower; or
2 NM from an airportwithout a published instrumentflight procedure or an operational tower; or 2 NM from a heliportwith a published instrument flight procedure Minimum crew for each operation will consist ofthe UAS pilot (PIC), the visual observer (VO} and may include but not limited to a camera operator The UAS pilot will be designated pilot in command and hold at least a Light Sport Pilot Certificate along with a Current State Drivers License. Ifthe PIC feels another operatorto be qualified with the necessary skills to be pilot in command and possesses at least a Light Sport Pilot Certificate along with Current State Drivers License, that person may be designated PIC provided they have a minimum of20 hours offlight time with the UAS. A briefing will be performed regarding the planned UAS operations priorto each day's flight consisting of all days production activities All flights will occur undervisual flight rules meteorological conditions (VFR only). The operatorwill obtain verbal/written consent ofall persons involved with the planned operations and ensure only consenting persons will be allowed within 100 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required underthe FOM. With the advance permission ofthe FFDO, operations at closer range may be approved. The PIC and VO will have been trained in operation of UAS and receive up-to-date information for the particular UAS to be operated. The PIC and VO will be able to communicate by voice, radio, and/ortext at all times. Written and/orverbal permission and permits will be obtained from territorial, state, county or cityjurisdictions, including law enforcement, fire or other appropriate governmental agencies. Ifthe UAS loses communications with the remote controller or losses GPS signal, the UAS will have the capability to return to a pre-determined location within a designated location and land autonomously. The UAS will have the capability to abort aflight and return to designated landing area in case of unpredicted obstacles, weather, or emergencies.

### VO or PIC instructed to switch UAS to automatically return home in event either are incapacitated. https://www.faa.gov/uas/legislative_programs/sectlon_333/how_to_file_a_petition/media/ section333 _publk_guidance.pdf

As ofMarch 23, 2015, the FAA will automaticallygrant a "blanket" COA for flights at orbelow ZOO 

### feet toanyUAS operatorwith a Section 333 exemption, providedthe aircraft weighs less than 55 pounds, operations are conducted during daytime Visual Flight Rules (VFR) conditions and within visual line ofsight (VLOS) ofthe pilots, and staycertain distances awayfrom airports orheliports.
In seeking authorization, petitioners will require exemptions from regulations with which they cannot fully comply. The table below provides guidance regarding regulations from which a petitioner may require exemption. However, some proposed operations may require exemption from regulations not listed here, while others may not require exemption from all regulations listed here. 14 CFR PART 21, Subpart H

91.103(b)(2) 91.105 91.109 91.119 91.121 91.151

91.405 91.407 91.409 91.417

Certification procedures for products and parts, Airworthiness Certificates

Preflight action Flight crewmembers at stations Flight instruction Minimum safe altitudes Altimeter settings Fuel requirements forflights in VFR conditions Maintenance required Operation after maintenance Inspections Maintenance

### 14C.F.R. Part 21. Subpart H: Airworthiness Certificates 14C.F.R. Sec 91.203(a)(1)
The UAS will operate @ 

### SSibs orless (Gross), carries neithera pilot orpassenger*, carries no explosive materials or flammable liquid fuels*, and operates in within a secured and pre-determined designated area, at altitudes not to exceed 200 feet ALT orspeedsin access of 100 MPH.
14C.F.R. Sec 91.105 Flight crew members at station Exemption maybe required, the PIC maynot leave his station nor shall VO leave station. In eventthat PIC orVO become incapacitated, UAS is to automatically return to designated landing area, as outlined inFOM

14CFR Sec 91.109 Flight Instruction (Dual Controls}
Requiringthat no person shall operate a civil aircraftfor flight instruction unless the aircraft hasfully functioning dual controls. UAS and Remote controlled aircraft by design do not have dual controls, to do so on a radio controlled aircraft would lowerthe abilityto safelyoperatethe UAS. This section cannot reasonablyapply

14C.F.R. Sec45.23(b). Marking ofthe Aircraft Although exemptionfrom said section cannot benefit nor exceed current stipulations, physical limitations ofUAV are reality, such as cabins, lettersize, ect.The UAV will operate under my control with registration lettering sized tofit fuselage in compliance ofsaid section 45.23(b) underconditions and orlimitations deemed mandatoryby FAA. My colleges and Imust be held responsiblefor compliancy, on behalfofPublic's safetyand shared air space, as well as its need to identify and enforcethe accountabilityand ofthisgrowing industry.
14C.F.R. Sec 61.113(a) and (b):

### Pfivati¥'PilotPri\lile~es and Limitations: Pilot in Command By current regulations becausethe applicants UAS does not carry passengers, orproperty.The use of UAS is far less dangerous (weight, speed, Fuel) than theinherent usage ofcommercial activities outlined in 14CFR.16. The pilot in command shall have a current Private pilotslicense as well as a current state drivers license which will equal ifnot exceed safetyregulations outlined in 14CFR 16.113.(a) & 

### (b).

14C.F.R. Sec. 91.103: PreflightAction: Exemption is requested due tofactthat FAA rotorflight manuals are not available for UAV. The PIC will take all actions as stated in FOM, under normal procedures included but not limited to review of weather, examination ofbatteriesforflight time analysis, landing and takeoffdistances as well as flight and aircraft performance in flight.

### 14 C.F.R. Sec 91.119: Minimum Safe Altitudes
Mandates safe altitudefor operation ofcivil aircraft and allow helicopterto operates less then minimums prescribed, providingthe person operating helicopter complieswith anyroute with and or altitudes prescribed for Helicopter's by FAA. Beingthat UAV is ofHelicopters standards and operation a requestfor exemptionto operate at altitude's notto exceed 200AGL ornot morethan 200ft above anyelevated platform from which take offis necessaryto achieved filming. In the event ofsuch particularflight plan, propertyowners,filming crews and other personnel would all be briefed as to safetyand conduct procedures during flight. FOB orATC havingjurisdiction in such area would have notification and briefing as mandated.
14C.F.R. Sec 91.121 AltimeterSettings
The requirementofPIC is to use altimeteras meansto navigate aircraftto cruise altitudesto and from corresponding airports as predetermined in flight plan, unless ordered otherwise. As the UAS has no barometric altimeter, but instead uses GPS altitude read out, an exemption would need be applied. Per a preflight checklist and live flight data monitoring, the altitude oflaunch site will be predetermined and therefore calculated into the UAS- GPS indicatorbeforeflight.
14C.F.R. Sec 91.1Sl(a): Fuel Requirementsfor Flight in VFR Co
Fuel requirementsfor flight. The maximum flight time under ideal conditions is 30 minuteswith the current manufacturers battery pack. The proposed rule underthis exemption would require the UAS to return to its point oflaunch ifits batteryreaches less than 25% provides a higher standard ofsafety when applied to UAS.
14 C.F.R. Sec 91.405(a); 407(a)(1); 409(a)(2); 417(a) & 

### (b): Maintenance Inspections Referringto maintenance, preventive maintenance, and alterationstothe UAS. The operatorwill provide minor maintenance and inspection tothe UAS, documented as outlined in the operational and safetyguidelines. Given the size and simplicity ofthe UAS combined with the operational and safetyguidelines outlined in this petitionthe operatorcan maintain orexceed the required level of safety.

Sincerely
Rod Cambridge 

# (U 

# t:tr