April21, 2015U.S. Dept. ofTransportation, Docket Operations West BuildingGround Floor, Room w12-140 1200 NewJersey Avenue, SE., Washington, DC 20590 Submitted Electronicallyvia the Federal Docket ManagementSystem (FDMS) Re: Exemption Request underSection 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: On BehalfofStephen Nadeau and Pursuantto Section 333 ofthe FAA Modernization and Reform Act of 2012 and 14C.F.R. Part 11, IStephen Nadeau, am seeking an exemption from Part 21 Subpart H; and Sections 91.203 (a) 

### (iL45.23 

### (b), 91.7 (a), 91.9, 61.113, 61.133, 91.109, 91.119, 91.121, 91.151, and (91.401- 91.417) Subpart E, ofTitle 14, Code of Federal Regulations (14 CFR). This proposed exemption would allowforthe operation ofour unmanned aircraft (UA) the DJIInspire 1, S1000, and Plexidrone for the purpose ofaerial image acquisition. 

### THE UNMANNED AIRCRAFT (UA):
• The UA's are lightweight (under5Sib. gross weightL battery operated 4-motorquad copters that takes offand landsvertically 

### THE UA INCLUDES:

• An on-board flight computer with GPS navigation and location ability that receives signals for flight controlsfrom aground-based transmitter/controller; • An on-board camera capable of capturing imagery in the form of full color, high definition still photos and video • An on-board telemetry system that delivers flight data from the on-board flight computertothe on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlightand direction backto its launch site • A5.8GHz on-board radiotransmitterthattransmits live video from the on-board camera plus all the flight data from thetelemetry system described above


### THE GROUND STATION PART OFTHE SYSTEM:
• A Pilot in Command (PIC) In operational control of a mission from beginning to 

### end, and who controlsthe UA while in the air • A2.4GHz radio transmitter/controlleroperated by the PICtocontrol the UA while in flight • Ground Station (computer, tabletfor smart phone based app) which receives and displays video and system telemetry real timefrom the UA • A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UA while inflight.

Stephen Nadeau SECTION 333 EXEMPTION REQUEST Page 

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### UAS OPERATING GUIDELINES: The UA will be operated in the field with both a PIC and aVO in accordance with and with the following Restrictions:

• All operations must occur in FAA Class Gairspace at no morethan 400ftAGL, at an airspeed of no morethan 25 knots and no furtherthan 3/4 NM from the PIC; • All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate by voice atall times during aflight operation; • The PIC musthave accumulated and logged, in a mannerconsistentwith 14 CFR § • 61.51 (b), 10 hours oftotal time as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot with asimilar UA type; • The UA will not be operated over densely populated areas; without priorapproval. • The UA will not be operated over any open-air assembly ofpeople; without priorapproval. • The UA will not be operated within 5 NM ofan airportor heliport;without priorapproval. • Operations will be restricted to day onlyand weatherconditions equivalenttoVFR; • The PIC will brieftheVO and property owneraboutthe operation and risk before operation • No flight will be made without a Pre-Flight Inspection by the PIC before each operation to ascertain thatthe UA is in acondition safe forflight 

### PILOT IN COMMAND (PIC) AND VISUAL OBSERVER: The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course ofmaintenance instruction as part oftheir initial training. Isubmitthatthe combination ofthe UA's light weight, flight performance and ability, fully qualified flight crew and strictoperation underthe guidelines established in 8900.227, and underall ofthe Restrictions listed above, the FAA can have full confidence thatthe operation will have an equivalentor greater level ofsafetythan manned aircraft performingthe same mission. 

### INTENDED USE: The requested exemption would allow us to use the UA for aerial image acquisition to support various mapping and surveying applications as well as video documentation for the public good. Typical applications would include, butare not limited to:
• Videography/ Film-making • Aerial Photography • Aerial Mapping • Volumetric Surveys • Architectural/Historical Preservation Surveys The inherent ability ofthe UA is to capture imagery from a low altitude including oblique photos and video from several angles is far more effective than ground- based imagery for displaying the characteristics of buildings, sites and properties or areas where consistent monitoring is needed. The applicant in the past has chartered fixed wing aircraft and/or helicopters for this purpose, which have proven more costly than many potential clients have been able to afford, resulting loss ofopportunities. Stephen Nadeau SECTION 333 EXEMPTION REQUEST Page 

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### 4The reduced cost and higherquality data from the UAwill be beneficial tothe public in applications such as preservation of historic buildings or archeological sites where access is limited and project sites potentiallysensitiveto disruption. 

### PUBLIC SAFETY: UA's, are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft running on combustible fuel; they operate at lower altitudes (under 400') with no people on board thereby reducing current risk levels and enhancing public safety. With a small payload and maximum flighttime ofapproximately 22 minutes, UA's offer little or no risk to national security. In addition the DJI UA has its own built in flight restrictions in special areas ie: airports, which limitflight in these areas. More information can be found in the UA's User Manual or on DJI's website at https://www.dji.com/flysafe. 

### SUMMARY GRANT REQUEST: This request follows many others using similar systems and process that have been granted previously. I am requesting the FAA issue asummary grant ofexemption as this request would not set aprecedent.
• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also applytothis request • Agrantofexemptionwould be in the public interest. 

### THE REGULATIONS FROM WHICH THE EXEMPTIONS ARE BEING REQUESTED Beside each regulation number is the page ofthe attached Addendum upon which each may be found togetherwith aproposed equivalent level ofsafetyfor each regulation:

- 14CFR Part 21 Subpart H Addendum Page 1

- 14 CFR 91.203 (a) (1) Addendum Page 1

- 14CFR 45.23 (b) Addendum Page 1 -14CFR 91.7 (a) Addendum Page 2

- 14CFR 91.9 Addendum Page 2

- 14CFR 61.113, 61.133 Addendum Page 2

- 14CFR 91.109, 91.119, 91.121 Addendum Page 3

- 14CFR 91.151 Addendum Page 3

- 14CFR Subpart E(91.401- 91.417) Addendum Page 4 -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) Addendum Page 4

I am prepared to modifyor amend any part ofthis request to satisfy the need for an equivalent level of safety. Please contact us at any time ifyou require additional information or clarification. I am the primary point ofcontactforthis request and lookforwardtoworking with youroffice.

Stephen Nadeau SECTION 333 EXEMPTION REQUEST Page 3 of

### 4Sincerely,

Stephen Nadeau Phone: 

### 978-930-3330 Email: ret.uscg@gmail.com Addendum Containing Exemption Requests and Equivalent Level of Safety Appendix A- Flight Operations/Procedures Appendix B-User's Manuals

Stephen Nadeau SECTION 

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### Stephen Nadeau SECTION 333 EXEMPTION REQUEST Page 5 of4

### ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY I, Stephen Nadeau, request an exemption from the following regulations as well as any additional regulations that maytechnically applytothe operations ofthe DJIInspire 1, 51000, and Plexidrone: 14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. 91.203 (a) 

### (1) Subpart H, entitledAirworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR 91.203( a) (1). Given the size and limited operatingarea associated withthe UA to be utilized by the Petitioner, an exemption from Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe FMRA. The Federal Aviation Act (49 U.S.C.44701 (f)) and Section 333 of the FMRA both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UA. In all cases, an analysis of these criteria demonstrates that the UA operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The UA to be operated hereunder is less than 55 lbs. fully loaded, is by definition unmanned and carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a limited flight area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by the Operator and will also remain within the requirements of, and in compliance with, local public safety requirements. These safety enhancements, which already apply to civil aircraft provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the UA due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inabilityto carry asubstantial external load.

14 C.F.R. 45.23 (b). Marking ofthe Aircraft The regulation requires; When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport/' "experimental/' or "provisional," as applicable. Even though the UA will have no airworthiness certificate, an exemption may be needed as the UA will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UA, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with 45.29 

### (f). The equivalent level ofsafety will be provided by having the UA marked on its fuselage as required by 45.29 (f) where the pilot, observer and others working with the UA will see the identification ofthe UA as "Experimental."

Stephen Nadeau EXEMPTION REQUESTAND LEVEL OF SAFETY Page 

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### The FAA has issued the following exemptions tothis regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A. 14C.F.R. 91.7(a): Civil aircraftairworthiness. The regulation requires that no person may operate acivil aircraft unless it is in airworthycondition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained herein for the use ofsafety check lists priorto each flight, an equivalent level ofsafety will be provided. 14 CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation; the documentation would not be available tothe crew duringflight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA Flight Operations/Procedures (Appendix A) must be available to the crew at the ground station anytimethe aircraft is in, or preparing for, flight. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299,9299A,9565,95658,10167, 10167A, 10602,32827, and 10700. 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot in command ofan aircraft for compensation or hire. Subparagraph {b) allows a private pilotto act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and {2} The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require thatthe PIC musteither

1. Hold a Private Pilot Certificate issued by the FAA, and have logged 10 hours of flight experience in this type ofUA, or 2. Meetthe requirements of 8900.227 para 16(c}{2}{c} "Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilot written examination." Since there are currently no means available forthe pilot ofa UAto gain the experience in an equivalent categoryand class in orderto applyfora private pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAA private pilot ground instruction and pass the FAA Private Pilot written examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel that we meet the intent of 61.113 Subparagraph (b) even though the intentofthis application is to conducta business. Stephen Nadeau EXEMPTION REQUEST AND LEVEL OF SAFETY Page 7 of414 CFR 91.109 Flight Instruction;Simulated instrumentflight and certainflighttests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unlessthat aircraft has fullyfunctioning dual controls." The UA's ground-based control station consists ofasmall hand-held radio transmitterand while itdoes not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety. 14CFR 91.119 Minimumsafe altitudes: General. The regulation states thatoversparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of400 feetAGL, we cannot complywith this requirement. In orderto provide an equivalent level ofsafetyThe UA's will not be operated over congested areas or over any open air assembly of persons with prior approval. Any property owner affected will be briefed on the expected route of flight and the associated risks to persons and property on the ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landingwithout undue hazard to persons or propertyon the surface. Therefore we maintain thatdue to the small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in grantingthe exemption. 14CFR 91.121 AltimeterSettings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter settingavailable within 100 NM ofthe aircraft. The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with otheraircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UA'S on-board computer to the display screen held by the PIC, providing aconstantly updated AGL readout. 14CFR 91.151 Fuel requirementsforflight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to flyto the first point of intended landing and to fly after that for at least 30 minutes. The intention ofthis paragraph is to provide an energy reserve as a safety buffer for delays to landing. Each UA is battery operated and the maximum duration of flight from a single battery charge is 18 minutes with a 20% reserve. Since the aircraft will never fly more than 3/4NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemption tothe word "fuel" and ask for an equivalent interpretationwiththeword "energy". Stephen Nadeau EXEMPTION REQUEST AND LEVEL OF SAFETY Page 8 of4

### 14CFR SubpartE(91.401- 91.417)- Maintenance,PreventiveMaintenance,Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthycondition, includingcompliance with part

### 39 and 

### 43. Paragraphs 

### 91.407 and 

### 91.409 require thatthe aircraft be "approved for return to service by a person authorized under 

### 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." As provided in the Pre-Flight Checklist in Appendix A, the PIC will ensurethatthe aircraft is in an airworthycondition priorto everyflight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updatingsoftware and firmware for the on-board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will documentwork performed in accordance with 

### 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety. 

### 8900.227 Paragraph 16(c)(4) PIC Medical.And Paragraph 16(e)(1) ObserverMedical. This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in orderto perform as a pilot or observer. The UA's maximum gross weight is less than 81bs., are constructed primarily of, plastic and carbon fiber. The PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as commercial pilot carrying passengers in alarge aircraft is an unnecessaryburden. We propose thatthe minimum medical requirements forthe PIC and VO be vision corrected to 20/20 and avalid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO n see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.

Stephen Nadeau EXEMPTION REQUEST AND LEVEL OF SAFETY Page 9 of4

### APPENDIX A- FliGHTOPERATIONS/PROCEDURES
The UA's will be operated underthefollowingflight restrictions.



### OPERATIONAL FLIGHT RESTRICTIONS The UA will be operated in the field with both a PIC and aVO in accordance with and with thefollowing Restrictions:
• All operations must occur in FAA Class Gairspace at no more than 400ftAGL, at an airspeed of no morethan 25 knots and nofurtherthan 3/4 NM from the PIC; • All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate by voice atall times during aflight operation; • The PIC must have accumulated and logged, in a mannerconsistent with 14CFR § • 61.51 (b), 10 hours oftotaltime as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot with asimilar UAtype; • The UA will not be operated over densely populated areas; without priorapproval. • The UAwill not be operated overany open-air assembly ofpeople; without priorapproval. • The UAwill not be operated within 5 NM ofan airportor heliport; withoutpriorapproval. • Operationswill be restricted to day onlyand weatherconditions equivalenttoVFR; • The PIC will brieftheVO and propertyowneraboutthe operation and risk before operation • No flight will be made without a Pre-Flight Inspection by the PIC before each operation to ascertain thatthe UA is in acondition safe forflight


### PRE-FliGHT CHECKLIST Priorto operation preflightchecklists provided bythe manufacturerofthe UA's will be followed. Below is such an example. 

### 1. Remote Controller, smart battery, Range Extender and smartphone are fullycharged. 2. Propellers are mounted correctly. 3. Damping absorbers are in good condition, not broken orworn. 4. Camera lens cap has been removed. 5. Micro-SO card has been inserted ifnecessary. 6. Gimbal is functioning as normal. 7. Motorscan startand are functioning as normal. 8. Smart phone App can connecttothe camera.

Stephen Nadeau-APPENDIX A- FLIGHT OPERATIONS AND PROCEDURES

### TAKE OFF/LANDING PROCEDURES Manufacturer recommended Takeoffand Landing procedures will be followed. Place the UA on ground withthe battery level indicatorfacing you. 

### 1. Poweron the remote controller. 2. Poweron the range extender. 3. Switch the camera tothe "WIFI ON" position. 4. Power on the aircraft byturning on the intelligent battery 5. Connect the mobile device to the UA, run the Smart phone App to enterthe camera preview page. 6. Wait untilthe LED flight indicator startstoslowly blink green/yellow.This means the aircraft is initializing and entering the "Ready to Fly";uReady to Fly (non-GPS)." state. Then proceed to execute the

# esc command tostart motors. 7. Push the throttlestick up slowlyto liftthe aircraft offthe ground. 8. When landing, be sure to be hovering over a level surface. Pull down on the throttle stick gentlyto descend and land. 9. After landing the aircraft on the ground, keep the throttle stick at its lowest position for about 3to5seconds which will automatically stop the motors. 

### FAILSAFE FUNCTION The UA will enter Failsafe mode when the connection from the remote controller is lost. The flight control system will automatically control the aircraft to return to home and land to reduce injuries or damage. The following situations would make the aircraft fail to receive a signal from the remote controllerand enter Failsafe mode: 

### 1. The remote controller is powered off. 2. The aircraft has flown outofthe effective communication range ofthe remote controller. 3. There is an obstacle obstructing the signal between the remote controller and the aircraft, essentially reducing the distance the signal can travel. 4. There is interference causing asignal problemwiththe remote controller.

Stephen Nadeau-APPENDIX A- FLIGHT OPERATIONS AND PROCEDURESAPPENDIX B-USER'S MANUALS DJI Inspire 1, S1000, and Plexidrone

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Stephen Nadeau -APPENDIX B-User's Manuals