December 14
, 2015

**Name and**  **Ad dress**  **of Petitioner:**  Chris Johnson 2469 Eureka Dr. Yuba City, CA 95991 530

-671

-6911 yubasutterdroneguy@gmail.com

Requestfor Exemption, Section 333 ofthe FAA Reform Act pertaining to Federal Aviation Regulations 14 CFR, Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l), 91.417(a)&(b)
I, Chris Johnson, as the petitioner, request exemptions in orderto legally operate Unmanned Aircraft Systems (UASs), a Yuneec Q500+ 4k (N69692 reserved and registration filed) and 3DR Solo (N69691 reserved and registration filed) in the National Airspace System. The Yuneec Q500+ 4k and 3DR Solo this petitionerseeks exemption to use will be referred to as ‘Named UASs’. All flights ofthe ‘Named UASs’ will be flown by line ofsight (LOS) and performed under 400' above ground line (AGL). The ‘Named UASs’ both have GPS guidance and "return to home" safetyfeatures installed. The ‘Named UASs’ also uses a smartphone to enhance controls by showing currentAGL and visual location ofthe ‘Named UASs’ to the subject and its surroundings. The petitionerwishes to be granted the exemption for use ofthe ‘Named UASs’ for commercial videography and photography of:
1. Residential and Commercial Real Estate and property, for marketing the sale of each. 2. Construction Process (Residential and Commercial), providing a visual review ofthe construction process to be used for marketing ofa construction company or documentation to be provided to the owner. 3. Film production used for purposes of television broadcast, movie production or private video/dvd production. 4. Property Inspection, providing a visual review of existing conditions to the land owner. 5. Property Landscape, provide visual documentation of ‘before and after’ improvement to
a land owner.

The Petitioner believes the use ofthe Yuneec Q500+ 4k and/or 3DR Solo is more economical and safe to use than a manned aircraftforthe aforementioned purposes. In the past, a manned aircraftwould be used to provide a visual review of land and property, which involves pilotfees, inspections,and use of an airport. Use ofthe ‘Named UASs’ ratherthan a manned aircraft is more economical to the consumer, and beneficial to the general public due to its small size, low noise, and minimal potential for accident.

Additionally, I the petitioner, would like to point out that in orderto own a successful business it is in my best interest to put safetyfirst. That safety directly benefits the public because safety also relates to protecting my investment in UASs. Ifthe UASs are damaged, so is my means of providing a service and profiting from it. Also, if I don’t provide a safe service to my customerstheywill be less likely to recommend me to their neighbors. So it is essential to provide a safe

service in orderto gain the trust ofother potential customers.
My requestforthe following exceptions are based on those provided to Exemption No. 11623, 11650, 11664, 11734, and 11189. I reviewed and quote these public letters because ofthe similarities to the use ofa UAS to capture photography and videography of real estate and construction for hire as well video production for film, television and private industry.

Requestfor Exemption, Section 333 ofthe FAA Reform Act pertaining to Federal Aviation Regulations:

**14 CFR**  **Part 21**  Certification Procedures For Products and Parts **REA SON**  **FOR EXCEPTION**  It has been determined that similar UAS’s do not require an airworthiness certificate as granted in Exemption No. 11623, 11650, 11664, 11734, and 11189.

**14 CFR**  **91.7(a)** Civil AircraftAirworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy condition. **REA SON**  **FOR EXCEPTION**  It has been determined that similar UAS’s do not require an airworthiness certificate, however the petitionerwill ensure airworthiness through the combined use ofthe manufacturer's Operations Manual and preflight checks.

**14 CFR**  **91.119(c)** Minimum Safe Altitudes:( c) Over otherthan congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closerthan 500 feet to any person, vessel, vehicle or structure. **RE AS** **ON FOR**  **EXCEPTION** The use of ‘Named UASs’ will be flown no higherthan 400’ AGL in LOS over developed and developing residential areas that may be considered congested areas. That will not always be the case when providing a ‘Property Survey’ flight because they could be conducted over empty lots or acreages with no structures. This will minimize the amount of bystanders present or in the surrounding area. In the case offlying over or near existing private propertywhile providing

a ‘Residential and Commercial Marketing’, ‘Construction Process’, ‘Property Inspection’, and ‘Property Landscaping’ landowners will be notified in person by the petitioner, or by a card lef t behind by the petitioner, of an occurring ‘Named UASs’ flight. The petitioner also proposes to display a caution sign on site while a ‘Named UASs’ flight is ongoing. The petitionerwill review with the landowners of associated risks to people and property. Due to the small size ofthe ‘Named UASs’ the associated risk to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be taken into consideration.**14 CFR**  **91.121**

Altimeter Settings: **RE AS** **ON FOR**  **EXCEPTION** The ‘Named UASs’ does not have a barometric altimeter. It does have a GPS that will calculate altitude. The petitionerwill limitflights to a maximum altitude of400 feetAGL as granted in Exemption No. 11623, 11650, 11664, 11734, and 11189.

**14 CFR**  **91.151(a)(l)** Fuel requirements forflight in VFR conditions:( a) No person may begin a flight in an airplane underVFR 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 afterthatfor at least 30 minutes. **RE AS** **ON FOR**  **EXCEPTION** The ‘Named UASs’ provides low batterywarnings to indicate when you should return the ‘Named UASs’ to the launch point. Afail safe automatic landing will occur ifthe battery reaches critical low voltage. The ‘Named UASs’ will be landed upon the 1st low battery alert.. The petitionerwill not initiate a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point. All flights will be done during the day and at an appropriate time as to not be a nuisance to others.

**14 CFR**  **91.405(a)** Maintenance required: Each owner oroperator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in Subpart E ofthis part and shall between required inspections,except

as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter. **REA SON**  **FOR EXCEPTION**  The petitioner shall inspect the aircraft priorto everyflight. The petitioner plans to follow manufacturer's recommended preflight checklist. Reference given to the Operations Manual.

**14 CFR**  **91.407(a)(l)** Operation after maintenance, preventive maintenance, rebuilding, or alteration: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding,

or alteration unless( 1 )It has been approved for returned to service by a person authorized under43.7 ofthis chapter **RE AS** **ON FOR**  **EXCEPTION** The petitionerwho has the responsibilityforthe operation and safety ofthe ‘Name UASs’ will followthe manufacturer's suggestions for maintenance and repair. Including the use of suggested replacement parts.**14 CFR**  **91.409(a)(l) &**  **(2)**

Inspections: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) An annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by 43.7 ofthis chapter; or (2) An inspection forthe issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. No inspection performed under paragraph (b) ofthis section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an "annual" inspection in the required maintenance records. **RE AS** **ON FOR**  **EXCEPTION** The petitionerwill follow manufacturer’s suggestions to ensure that the ‘Named UASs’ is in a condition forsafe flight.

**14 CFR**  **91.417(a) &**  **(b)** Maintenance Records: (a) Exceptforwork performed in accordance with 91.411 and 91.413, each registered owner or operatorshall keep the following records (l)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v)( vi) forthe periods specified in paragraph (b) ofthis section: ( 1 )(2)(3) **REA SON**  **FOR EXCEPTION**  The petitionerwill keep a record ofall repairs and modifications. The petitioner also proclaims to
use approved manufactured parts for repairs and modifications.

**SUMMA RY**  I, Chris Johnson the petitioner requestfor exemption, Section 333 ofthe FAA Reform Act pertaining to Federal Aviation Regulations 14 CFR, Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l), 91.417(a)&(b) in orderto legally operate the Unmanned Aircraft Systems (UASs), a Yuneec Q500+ 4k and 3DR Solo, in the National Airspace System in orderto take aerial video and photography of real estate, construction processes, and purposes of video production.

Respectfully submitted,

Chris Johnson