Ambrose 333 petition Recognizing the demand to expedite integration of UAS into the NAS, the FAA is developing a regulatory framework for safely integrating UAS into routine NAS operations. The first stage in this process will be accomplished by

the small UAS rule. The FAA’s authority to issue exemptions from operating rules, and the Secretary’s authority granted by Section 333 of P.L. 112

- 95, Special Rules for Certain Unmanned Aircraft Systems , provide an opportunity to authorize certain UAS operations in the NAS prior to implementation of the small UAS rule. This incremental step provides a pathway for civil operators who desire safe and legal entry into the NAS. 3 Rev. 9/25/2014

**A PETITI ON FOR EXEMPTION IS**  

## TO CONDUCT FLIGHTS IN A UAS UNDER 55 LBS FOR OTHER **THAN HOBBY OR RECREATION: FOR BUSINESS PURPOSES**

**.** Regarding the Unmanned Aircraft System 1. **Petitioners should describe how the proposed UAS operation will be safely conducted**  **to mini mize risk to the NAS or to persons and**  **property on the ground. Specifically, petitioners should describe the design and operational characteristics for the type(s) of UAS they**  **intend to operate, e.g. aircraft performance and performance limitations, operat ing procedures, and aircraft loading information in as**  **much detail as possible.** This could be provided in the petition or in an Aircraft Flight Manual or similar document. 

## MY RESPONSE

**The under 55 lbs**  **UAV is a P hantom 2 as manufactured by DJI.**  **The unit has a built in sensor and barometric altimeter that measures both attitude and altitude, and the compass reads**  **geomagnetic information which assists the Global Positioning System to accurately calculate the aircraft position and hei**  **ght in order to lock the aircraft in a stable hover,**  **when the controls are released**  **..this is**  **be lost, the Phantom 2 has a FAILSAFE function which will maneuver the UAV to return to the home point and land. In the event the Phantom is unable to asses enough GPS**  **satel lites to determine home position it will descend in a controlled manner and land.**  **Risk to the NAS is eliminated in two areas, one, the under 55 lbs. UAV will maintain position in a hover should control inputs be ineffective and two, the petitioner, (**  **James Ambrose) who will be the operator, is an FAA Commercial Pilot ASEL MEL, and a Certified Flight Instructor** 
**** **Instrument, ASEL. I am very aware of the NAS, it’s various classes, there will be NO operations**  **in controlled airspace, and I underst**  **and 91.119 still applies as far as minimum safe altitude.**  **The Phantom 2 ( mfctr by DJI) has a loading portal to mount a ZENMUSE gimbal that is designed to attach a H3D3 Go Pro Camera. With the ZENMUSE gimbal and GO PRO H3D3**  **camera mounted on the Phan tom 2, the total weight is still significantly below the 55 lbs. ( approx.**  **3 lbs). The Phantom 2 was designed and manufactured to be operated in a safe manner fully loaded with the camera and gimbal or without. The petitioner has operated the UAV wi**  **th and without the camera and gimbal mounted and noted minimal performance variance.**  **Additional safety features include LED indicators on the unit and visible to the operator. They include an indication of the self test feature of the UAV. During thi**  **s self test, the unit is acquiring sateliites, testing on board mechanical links and digital system readiness. In addition it is**  **providing power level indication and confirms there is a strong signal from the controller. The on board self test syste**  **m also evaluates compass accuracy and effectiveness and will not allow flight if**Ambrose 333 petition

**there is a ferro**
**- magnetic interference or the compass needs calibration. The unit will not respond**  **to operator control to initiate flight until all system tests pass. A**  **n additional safety feature added to this unit is propeller guards. The petitioner has no intention to operate the UAV in close proximity to people or persons where a potential prop strike**  **could occur, but it does provide that higher level of safety in the completely unlikely event that**  **situation could exist.**



## Performance data **Max ascent speed 18 feet/sec descent speed 6 feet /sec Max flight speed approx. 25 MPH** 

2 . Petitioners should describe any procedures they would implement, such as pre - flight inspections , maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This could be provided in the petition, an Aircraft Flight Manual, a Maintenance and Inspection Manual, or similar document. 6 Rev. 9/25/2 014
**I ( the petitioner) as a FAA certificated pilot and Certified Flight Instructor have developed habits for thorough pre** 
**- flight inspections, pre** 
**- flight planning, to insure safe flight. I will apply**  **these habits to the safe operation of my under 5 5lbs UAV.**  **I intend to use the following pre**
**- flight planning, pre flight aircraft check and create a**  **nd follow a**  **flight plan when operating the Phantom 2.** 

## Pre
**- flight planning:**  **Weather check and evaluate if conditions are conducive for safe flight. Location for flight to occur is not in controlled airspace, is clear of any people or obstacles**  **that can impair the purpose and safe operation of the flight, and has no potential to contribute to any safety concerns of any other activity being con**  **ducted in the area of the flight.**  **I will discuss with the intended customer if the flight is to be used for business purposes what the objective of the aerial operation is to be; insure it could be conducted under all**  **the safe and appropriate gu idelines and inform the client he or she cannot interfere in any**  **way with my operation of the UAV. An agreement on the intended flight will be reached, as to the manner and space the UAV will operate. The flight will only occur once this**  **unders tanding is reached and will terminate immediately if the client interferes in any way**  **with the space I will require away from any and all people during the operation of the UAV.**  

## Pre
**- Flight Aircraft check:** Ambrose 333 petition

**Physical inspection of the entire unit for all mechanical connections tight and secure and cabling tight and secure. Feel prop edges for nicks or dents and replace with spare prop**  **prior to flight. Confirm ZENMUSE gymbal secure and all fasteners h ave plastic detent**  **rings on posts. Visually inspect camera mount and check bracket screws as tight with device wrench. Install battery unit and confirm firmly inserted and secure. Inspect LED**  **indicator covers and confirm tight, secure and u nobstructed. Inspect by gently applying**  **force to insure landing gear is not cracked and stressed and is firm and secure. Visually inspect each electric motor from the top to insure no debris has entered into the cooling**  **windings and each motor turns freely. Inspect and apply gentle force to insure each prop**  **guard is not cracked or stressed and is tight and secure.**


## Pre
**- Flight Flight Plan.**  **Determine a flight plan prior to flight that includes duration of flight, purpose of flight, intended heights and maneuvers in order to accomplish the mission for the flight as well as**  **the ability to maintain AT ALL TIME VLOS Rehearse the flight plan prior to launch by verbally explaining what the flight plan will be.**  **Determine th e flight time, with noted times to finish each critical leg of the mission and a**  **turn the flight time back to the launch site. Make a final review of the airspace and surroundings to insure the flight can be conducted**  **in a safe and legal manner .**  

## Launch **Check List Launch site clear and space adequate for safe launch and recovery of the**  **UAV. A Timer with the operator is set to 0 and ready for start**  **UAV battery on; confirm LED indicators showing pre**
**- flight**  **self**
**- test.**  **LED soli d green, start timer, launch UAV and hold at a 8 to 10 foot**  **vertical ascent above launch site, allow to hove r**  **for 15 seconds to insure aircraft is in a proper flight mode and is capable of hovering.**  **Apply all the control inputs one at a time t o insure the aircraft is**  **responding to the appropriate control inputs. Once successful self hover and control inputs are tested and confirmed accurate, continue flight.**  

## Conduct flight, read timer follow flight plan. Return to launch site **when return to launch site time is reached** Ambrose 333 petition



## Landing Check List **Visually inspect landing site, instruct all people to clear the site. Hover briefly above**  **landing site to visually inspect aircraft and note any abnormalities to check before next flight.**  **Land the aircraft, shut down the motors, secure aircraft.**Ambrose 333 petition . The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

## The unit operates in the 2.4HGz **ISM and meets FCC requirements.**
Regarding the Unmanned Aircraft PIC 4 . Petitioners should describe the qualifications required of any PIC(s) who will be directly responsible for the operation of the UAS, including information such as: the level of airman certificate held; any applicable training related to the operation; and any minimum hours of flight experience required by the PIC(s), both total flight time and the time with the particular UAS. If the operation would use visual observ ers, petitioners should describe their roles and qualifications. 5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible for the operation o f the UAS. 

## I am the operator and petitioner and I currently hold an FAA 3rd c **lass medical certificate, commercial ASEL, MEL certificate CFI** 
**- I and I am**  **current and active as a CFI. I intend to maintain my currency and medical according to the FAA guidelines, and I intend to apply the same rules and**  **vigilance as it relates to medic al and physical condition necessary for flight in**  **manned aircraft to the PIC** of this UAV. Regarding the Operation of the Unmanned Aircraft 6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how the proposed operation( s) would not adversely affect safety, or how they would provide a level of safety at least equivalent to that provided by the rule from which exemption is sought. Petitioners should address any plans to implement clearly defined operational borders and procedures to ensure public safety, which includes persons and property both in the air and on the ground. This can be described in th e petition, in an Operations Manual, or similar document. 

## My intended use is to use the camera feature to provide a service to individuals **and business where a low altitude aerial view would be helpful in what they were trying to evaluate or accomplish.**  **I intend to assess the mission as to what is expected to be accomplished,...then**  **review all of the safety parameters. Airspace, proximity to other property and people, any potential violation of a person or persons privacy, flight time to**  **accom plish the mission, weather affecting the mission, and condition and**  **performance capabilities of the UAV to accomplish the mission. Each will be reviewed and evaluated as part of the pre flight plan explained above.** Ambrose 333 petition 7. Petitioners should specify the proposed maximum operating speed and altitude, and describe minimu m flight visibility and distance from clouds for their intended operation(s). Petitioners should describe potential hazards and safety mitigations associated with these proposed conditions. These issues can be addressed in the petition, an Operations Manual, or similar document. 

## The intended speed will be less than 5 MPH as the UAV is positioned for still **photography or video. It will operate below 400 feet and in relatively calm winds and high overcast to clear skies. I see no hazards apparent in th**  **ese operating ranges.** 

8. Petitioners should describe the characteristics of the area of intended operation(s) and the associated potential hazards, in accordance with the statutory mandate under Section 333 7 Rev. 9/25/2014 

## The characteristics of the **operation will be based on the mission. In almost all cases it will be a very slow, very low altitude photo mission. The mission will**  **be carefully reviewed to determine any and all potential hazards are identified and the risk mitigated before the flight**  **takes place. This would include proxim** **ity to other property, people or persons, potential privacy issues and potential controlled airspace penetration.**  9. Petitioners should describe if they intend to operate in the proximity of any airports, in accordance with the statutory mandate under Section 333 regarding proximity to airports. 

## I am**a FAA pilot ASEL MEL CFI**
**- I and totally familiar with the Sectional**  **Chart and NAS. I am also very familiar with all the local airports. I will adhere to the st**  **atutory m andate regarding proxim** **ity to airports.** 10. The UAS must be operated within visual line

- of

- sight (VLOS), in accordance with the statutory mandate under Section 333(b)(1). Petitioners should describe how they intend to comply with his mandate.

**T HE VLOS requirement will be a critical part of the pre** 
**- flight planning and the final flight plan. The flight**  **will be scrubbed or altered to prevent a loss of VLOS.**

11. Petitioners should describe any procedures they would implement for conducting a preflight safety risk assessment to determine that the UAS is in a condition for safe flight (14 CFR § 91.7(b)) and that the plannedAmbrose 333 petition operation can be completed safely. The se procedures can be addressed in the petition, an Aircraft Flight Manual, Operations Manual, or similar document. I answered this in section 2 in but will repeat it here: **I ( the petitioner) as a FAA certificated pilot and Certified Flight Instruct or have developed**  **habits for thorough pre**
**- flight inspections, pre** 
**- flight planning, to insure safe flight. I will apply**  **these habits to the safe operation of my under 55lbs UAV. I intend to use the following pre** 
**- flight planning, pre flight aircraft che**  **ck and create a follow a flight plan when operating the Phantom 2.**  

## Pre
**- flight planning:**  **Weather check and evaluate if conditions are conducive for safe flight. Location for flight to occur is not in controlled airspace, is clear of any people or**  **obstacles that can impair the purpose and safe operation of the flight, and has no potential to**  **contribute to any safety concerns of any other activity being conducted in the area of the flight.**  **I will discuss with the intended customer if the flight is to be used for business purposes**  **what the objective of the aerial operation is to be; insure it could be conducted under all the safe and appropriate guidelines and inform the client he or she cannot interfere in any**  **way with my operatio n of the UAV. An agreement on the intended flight will be reached,**  **as to the manner and space the UAV will operate. The flight will only occur once this understanding is reached and will terminate immediately if the client interferes in any way**  **with the space I will require away from any and all people during the operation of the UAV.**  

## Pre
**- Flight Aircraft check:**  **Physical inspection of the entire unit for all mechanical connections tight and secure and cabling tight and secure.**  **Feel prop edges for nicks or dents and replace with spare prop prior to flight. Confirm ZENMUSE gymbal secure and all fasteners have plastic detent**  **rings on posts. Visually inspect camera mount and check bracket screws as tight with device**  **wrench. Install battery unit and confirm firmly inserted and secure. Inspect LED indicator covers and confirm tight, secure and unobstructed. Inspect by gently applying**  **force to insure landing gear is not cracked and stressed and is firm and s ecure. Visually**  **inspect each electric motor from the top to insure no debris has entered into the cooling windings and each motor turns freely. Inspect and apply gentle force to insure each prop**  **guard is not cracked or stressed and is tight and secure.** 


## Pre
**- Flight Flight Plan.**  **Determine a flight plan prior to flight that includes duration of flight, purpose of flight, intended heights and maneuvers in order to accomplish the mission for the flight as well as**  **the ability to maintain AT ALL TIME VLOS** Ambrose 333 petition

**Rehearse the flight plan prior to launch by verbally explaining what the flight plan will be. Determine the flight time, with noted times to finish each critical leg of the mission and a**  **turn the flight time back to the launch site. Make a final review of the airspace and surroundings to insure the flight can be conducted**  **in a safe and legal manner.**


## Launch Check List **Launch site clear and space adequate for safe launch and r ecovery of the**  **UAV. A Timer with the operator is set to 0 and ready for start**  **UAV battery on; confirm LED indicators showing pre**
**- flight**  **self**
**- test.**  **LED solid green, start timer, launch UAV and hold at a 8 to 10 foot vertical ascent ab**  **ove launch site, allow to hove for 15 seconds to insure aircraft is in a proper flight mode and is capable of hovering.**  **Apply all the control inputs one at a time to insure the aircraft is responding to the appropriate control inputs. Once s**  **uccessful self hover and control inputs are tested and confirmed accurate, continue flight.**  

## Conduct flight, read timer follow flight plan. Return to launch site when **return to launch site time is reached**

12. If petitioners intend to conduct operations which have existing requirements to notify Flight Standards District Offices (FSDOs) prior to operations

– such as motion picture and television filming, or pipeline and powerline patrol

– petitioners should describe their intended coordination in this regard for their proposed operation(s). 

## NO NOT APPLICABLE TO MY OPERATION AND UAV