UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

March 20, 2015

Dear Sir or Madam, I, Jonathan Held, am writing pursuant to the FAA Modernization and Reform Act of 2012 Section 333 and the procedures contained within 14 C.F.R. 11, to request exemption from the Federal Aviation Regulations listed below so that I may operate a
small Unmanned Aircraft System (sUAS) within the National Airspace System for the purpose of high resolution commercial aerial photography and videography

. I am a licensed pilot (ASEL, ASES, Glider) and instructor (CFIG). Because of this I have a full understanding of the value of aircraft inspection, maintenance, flight safety

awareness and procedures

, and use of the National Airspace System. Furthermore I have over 100 hours of experience flying a n Unmanned Aircraft ( UA )

.

The UA (henceforth called the P2 Mulitrotor) for whic h I seek exemption is a custom

built vertical take

- off 8 motor multirotor system with a maximum gross weight of 3 2 pounds and dimensions of 56 inches in diameter and 20 inches in height. The system is electrically powered by Lithium Polymer batteries and h as a maximum speed of 4 0 knots

. The P2 Multirotor incorporates multiple safety measures including an auto land feature in the event of a lost communication or GPS link, motor redundancy to assure controlled flight in the case of a motor failure, frequency hopping radio technology to prevent control loss due to radio interference, telemetry to monitor battery power during flight, and the use of a robust and reliable flight controller. The P2 Multirotor operation follows safety procedures and operating limit ations (including preflight checklist) set out in the P2 Multirotor Pilot Operators Handbook.

Respectfully submitted,

Jonathan William Held P2 PhotographyI. Contact Information:

Jonathan William Held

119 Loma Alta Drive
Oceanside, CA 92054

jon@p2photography.net (858)

- 602

- 2839

CFIG 3150235

II. The Specific Sections of Title 14 of the Code of Federal Regulations Fro m Which

I S eek R elief:

61.113 (a) Private Pilot Privileges and Limitations 91.7 (a) Civil Aircraft Airworthiness 91.119 (b) a n d (c) Minimum Safe A ltitudes

91.121 Altimeter S ettings

91.151 (a)(1) Fuel R equirements for Flights in VFR C onditions 91.405 (a) Maintenance R equired 91.407 (a)(1) Operation After M aintenance 91.409 (a)(1) and (2) Inspections 91.417 (a) (iii) and (b) Maintenance records

III. Extent of R elief and the R eason for R equesting S uch R elief:

I request an exemption from 14 C.F.R. 61.113 (a) so I may fly the P2 Multirotor (a powered aircraft) commercially on the basis of my Private (ASEL) rating.

I seek relief from C.F.R. 91.7 (a) , as the P2 Multirotor does not have an airworthiness certificate and no standard exists for determining airworthiness.

Considering that the most desirable range of altitudes for photography and videography

from a UA is b etween 20 and 500 feet, I request an exemption from 14 C.F.R. 91.119 (b) with the exception of flight over an open air assembly of persons or any person not

involved with the UA flight directly. To keep 1000 feet above the highest obstacle within

a 2000 fo ot horizontal radius would require the UA to fly higher than is safe. Furthermore, to keep 1000 feet above the highest obstacle within 2000 feet would defeat a commonly requested use of a UA, which is low altitude photography of buildings and structures.

S imilarly I request an exemption from 14 C.F.R. 91.119 (c) as it would prove difficult in

many practical situations to takeoff and execute flight while keeping 500 feet away from any person, vessel, vehicle, or structure. I propose that the P2 Multirotor maximum

altitude be established at 500 feet Above Ground Level.

Furthermore I propose that P2 Multirotor flight operations would be prohibited while

non

- participating persons are within 1 00 feet of the UA unless those persons remain in orunder structura l protection during the flight, or if those persons are necess ary to the purpose of flight, there is no undue hazard to them and they have been given a detailed safety briefing. Nevertheless, all persons shall stand back at least 25 feet during takeoff

and landing.

Due to the local and low altitude flight profile of the P2 Multirotor I seek exemption from

14 C.F.R. 91.121 . Furth ermore the P2 Multirotor has a GPS altimeter which is set to read 0 (zero) feet at the takeoff point prior to each flight. All P2 Multirotor flights are “local”, and unaided visual contact is maintained with the aircraft during all flight operation.

The P2 Multirotor is electrically powered and carries no fuel onboard therefore I request an exemption from 91.151 (a) (1)

.

The P2 Multirotor has no airworthiness certificate and there is no person authorized to perform the required inspections and maintenance therefore I request an exemption from 14 C.F.R. 91.405 (a)

.

The P2 Multirotor has no airworthiness certificate and there is no person authorized to return of the aircraft to service therefore I request an exemption from 14 C.F.R. 91.407 (a)(1)

.

The P2 Multirotor has no airworthiness certificate and there is no person authorized to perform an annual inspection therefore I re quest an exemption from 14 C.F.R. 91.409 (a)(1) and (2)

.

The P2 Multirotor has no airworthiness certificate and there is no person authorized to log maintenance records nor to approve the aircraft for return to service therefore I request an exemption fro m 14 C.F.R. 91.417 (a)(iii) and (b)

.

IV. The R easons W hy G ranting M y R equest W ould b e i n the P ublic I nterest or H ow
I t W ould B enefit the P ublic as a W hole :

Because of the passage of the FAA Modernization and Reform Act of 2012 specifically

TITLE III subtitle B

- Unmanned Aircraft Systems it is a priori knowledge that the integration of s UA S into the National Airspace System is in the public interest. Specific to my request however is the rapidly growing need and desire for quality aerial photographs and videography. It is my intent to make use of the P2 Multirotor to address those needs. While it is commonly known that a UA is a great tool for low altitude aerial photography and videography , it is not so well understood that the use of a UA often

allows for better aerial photography and videography in general. Since the UA and Pilot In Command are present at the site of interest, the photographer or videographer has the ability to wait until the conditions (of light etc.) are at an optimum. When operatin g from a manned aircraft this is rarely the case. Manned aircraft typically launch many miles from the site of interest and thus a photographer or videographer must accept the conditions of lighting that are found upon arrival. The public benefit of better images isvery real both economically and aesthetically. Furthermore a manned aircraft is loud

whe n it dwells over a given site whereas a UA is far quieter and will result in quieter skies and less complaints. In addition the FAA Office of Aviation Policy and Plans has

stated ( in the Notice of Proposed Rulemaki n g Regulatory Evaluation

, Small Unmanned Aircraft Systems 14 CFR Part 107 , page 17) , “ Consequently, once a small UAS aerial photography market becomes established, it would increase safety by substituting an unmanned aviation operation using a very light aircraft for a more complex manned aviation operation that uses a much heavier aircraft. A heavier manned aircraft would pose more risk to the public in the event of an acci dent. This market would also generate significant cost savings to the economy

. ”

V. The R easons W hy G ranting the E xemption W ould N ot A dversely A ffect S afety

or H ow the E xemption W ould P rovide a L evel of S afety T hat is at L east E qual to

the L evel P rovided by the R ule F rom W hich R el ief is Sought:

General : I have been a commercial pilot and flight instructor since 2006 and a rated pilot since 1998. I have 29 years of experience using the National Airspace System. I al so have more

than 100 hours of UA experience without incident. As is done with manned flight, any UA flight should and will be conducted with appropriate consideration to the safety of persons, property and other aircraft. This includes the use of a written takeoff checklist, regular ai rcraft maintenance and inspection, reference to weather information, airspace maps, aircraft manuals, use of a visual observer, etc. The P2 Multirotor is an octocopter with 8 motors. The loss of any one motor will not affect the ability of the aircraft to maneuver and land safely. The P2 Multirotor has battery power monitoring telemetry and

uses an XAircraf t SuperX flight controller that has an automated return home feature which will land the aircraft safely in the event of loss of the radio control commun ication or GPS link. Furthermore the SuperX is proven as a reliable flight controller and has no reported "fly a ways" as is the case with some other flight controllers. The P2 Multirotor radio transmitter and receiver operate on a 2. 4 GHz frequency and util ize frequency

hopping technology

, which provides superb protection from potential radio interference. In addition the FAA Office of Aviation Policy and Plans has stated (in the Notice of Proposed Rulemaki ng Regulatory Evaluation, Small Unmanned Aircraft Systems 14 CFR Part 107, page 17) , “ Consequently, once a small UAS aerial photography market becomes established, it would increase safety by substituting an unmanned aviation operation using a very light aircraft for a more complex manned aviation opera tion that

uses a much heavier aircraft. A heavier manned aircraft would pose more risk to the public in the event of an accident. ”

61.113 (a) Private Pilot Privileges and Limitations : Although I do not have a commercial power rating I believe the knowled ge and skill set of my commercial glider and instructor rating (CFIG) to be sufficient for safe commercial operation of the P2 Multirotor. I have logged over 500 hours instructor time in gliderswith over 1300 hours pilot in command. I also hold ASEL and A SES ratings and a third

class medical certificate.

91.7 (a) Civil Aircraft Airworthiness : The P2 M ultirotor has no airworthiness certificate so no standard exists for airworthiness. However, regular airworthiness inspections and maintenance will be carri ed out, including preflight preparation and preflight procedures including a preflight checklist. Furthermore, compliance with all operating documents , manufacturers recommendations, safety bulletins, and airworthiness inspections will be faithfully carrie d out by the owner/operator in the spirit of the safety considerations of any relevant C.F.R.'s. I have maintained, inspected and flown a UA for several years without incident.

91.119 (b) and (c) Minimum Safe Altitudes : To be useful the P2 M ultirotor must be able to fly below 1000 feet above the highest

obstacle and within a 2000 foot radius. The small size, low weight, tight maneuvering capability, vertical takeoff profile, flight controller reliability

, motor redundancy and the

lac k of combustible f uel onboard the P2 Multirotor allow for its safe use at lower altitudes and in closer proximity to persons and structures than the altitude and distance limitations required by 91.119 (b) and (c). 14 C.F.R 91.119 ( d ) exempts helicopters

from the limitati ons of 91.119 (b) and (c). While the P2 Multirotor is not a helicopter (owing to the fact that it does not have engine

- driven rotors), it is a rotorcraft and it is intended primarily for hovering. I propose that the P2 Multirotor can operate safely

within the limitations of 91.119 (d). More specifically I propose (as stated in the P2 Multirotor Pilot Operating Handbook section 2) that P2 Multirotor “ flight operations are

not allowed while non

- participating persons are within 1 00 feet of the UA unless those persons remain in or under structural protection during the flight, or if those persons are

necessa ry to the purpose of flight, there is no undue hazard to them and they have been given a detailed safety briefing. Nevertheless, all persons shall sta nd back at least 25 feet during takeoff and landing. ”

The current standard limitation of a 400 foot AGL maximum altitude for a UA in itself does not provide adequate safety. Helicopters regularly fly below 400 feet, and while airplanes are theoretically r equired to fly above 500 feet AGL (except in proximity of an airport), it certainly is possible that one will be flying below 400 feet for a variety of reasons. The point is that visibility

, traffic identification and collision avoidance are necessary for safe operation. Safe UA flight requires that the Pilot In Command and/or the Visual Observer identify traffic in a timely fashion that will allow the UA to effectively maneuver out of the way. See and avoid is the key to safe operation. The

altitude and f light path of the P2 Multirotor is always constrained by the consideration of timely air traffic collision avoidance. The P2 Multirotor will always remain clear of and give way to any manned aircraft operations as well as giving way to any other UA or hazard deemed to pose a collision threat. Therefore I propose that the P2 Multirotor can operate safely to a maximum altitude of 500 feet Above Ground Level or ( as stated in the P2 Mulitrotor Pilot Operating Handbook section 2 )

, “ Flight altitude sh all not exceed 500

feet AGL ”

.91.121 Altimeter Settings : The most useful and relevant altitude information for any P2 Multirotor flight is the height above ground level. The P2 Multirotor has a GPS altimeter which is set to 0 (zero)

elevation at the tak eoff site. The GPS altimeter has a proven accuracy. Concerns regarding the altimeter reading should be alleviated by the fact that all P2 Multirotor flights are local line

- of

- sight in a confined area in Visual Meterological Conditions. Visibility is paramo unt and see and avoid is always in play. A Visual Observer is always onsite during P2 Multirotor flights to act as a traffic spotter. The AIM 7

- 2

- 3 describes 75 feet as the maximum acceptable error in barometric altimeters. If an airplane were flying

at 5 00 feet AGL by reference to a barometric altimeter with a 75 foot error then it may be flying as low as 425 feet. Again I state that see and avoid is what provides the element of safety.

91.151 (a)(1) Fuel requirements for Flights in VFR Conditions : The P2 Multirotor carries no fuel as it is an electrically powered aircraft. However, adequate power reserves for extended flight in the case of unexpected situations can be readily achieved by flight planning and power consumption telemetry such that the retu rn to the landing point and the landing will be accomplished with at least 25% battery power remaining.

91.405 (a) Maintenance Required : Since the P2 Multirotor has no airworthiness certificate the owner/operator will be responsible for the maintenance, repairs and alterations of the P2 Multirotor. Such

maintenance will be carried out in accordance to the manufacturers recommendations and in the spirit of the safety considerations of the relevant C.F.R.s. As owner, operator and

Pilot In Command of the P 2 Multirotor it is in my best interest to ass ess its condition at all times and to provide quality service and repairs. I have maintained, inspected and

flown a UA for four years without incident.

91.407 (a)(1) Operation After Maintenance : The owner/operator will be responsible for the approval of the aircraft for return to service as well as making logbook entries of such approval. As the owner, operator and Pilot In Command of the P2 Mulitrotor I am the person most intimately aware of the condition of my aircraft. It is in my best interest to track its service and repair history and

to assess it s condition at al l times. I have maintained, inspected and flown a UA for four

years without incident.

91.409 (a)(1) and (2) Inspections : The owner/operator will be responsible for the inspections an d maintenance of the P2 Multirotor. As the owner, operator and Pilot In Command of the P2 Mulitrotor it is in my best interest to assess its condition at regular and frequent intervals. Inspections w ill be made in the spirit of the safety considerations of the relevant C.F.R.'s. I have maintained

, inspected and flown a UA for four years without incident.

91.417 (a)(iii) and (b) Maintenance records :The owner/operator will be responsible for logging of maintenance, repairs, alterations and inspections. The owner/operator will be responsible for the approval of the aircraft

for retur n to service. It is in my best interest to track the service and repai r history of the

P2 Multirotor and to assess its condition at all times. I have maintained, inspected and

flown a UA for four years without incident.

VI. Summary for P ublic D istribution : 1) I, Jonathan Held, seek relief from the FAR Part 14 Sections lis ted below so that I may legally operate a small Unmanned A ircraft System (sUAS) within the National Airspace System for the purpose of high resolution commercial aerial photography and videography :

61.113 (a) Private Pilot Privileges and Limitations

91.7 (a) Civil Aircraft Airworthiness 91.119 (b) and (c) Minimum safe altitudes

91.121 Altimeter settings 91.151 (a)(1) Fuel requirements for flights in VFR conditions 91.405 (a) Maintenance required 91.407 (a)(1) Operation after maintenance 91.409 ( a)(1) and (2) Inspections 91.417 (a)(iii) and (b) Maintenance records

I am a licensed pilot (ASEL, ASES, Glider) and instructor (CFIG). I have a full understanding of the value of aircraft inspection, maintenance and flight safety procedures and use of the National Airspace System. Furthermore I have 4 years of experience flying a n unmanned aircraft ( UA )

.

The multirotor (hereafter called the P2 Multirotor) for which I seek exemption is a

custom built vertical take

- off system with a maximum gross weigh t of 3 2 pounds and dimensions of 56 inches in diameter and 20 inches in height. The system is electrically powered by Lithium Polymer batteries and has a maximum speed of 40 knots . The P2 Multirotor incorporates multiple safety measures including an auto land feature in the event of a lost communication or GPS link, motor redundancy to assure controlled flight in the case of a motor failure, frequency hopping radio technology to prevent control loss due to radio interference, telemetry to monitor battery p ower during flight and the use of a robust and reliable flight controller. The P2 Multirotor operation follows safety procedures and operating limitations set out in the P2 Multirotor Pilot Operators Handbook. An equivalent level of safety has been descri bed for each requested C.F.R. exemption and my years of experience using the National Airspace System will provide

an additional level of safety during flight operations.

2) Description of the N ature of the E xemption s S ought : The exemptions sought are to allow the use of a UA for commercial purposes (aerial photography and videography ) without an airworthiness certificate but under the safety guidelines set forth by the FAA for UA operation.61.113 (a) Private P ilot Privileges and Limitations: Exemptio n will allow the private pilot certificate holder to fly the UA commercially.

91.7 (a) Civil Aircraft Airworthiness: Exemption will allows the owner/operator to determine the airworthiness of the UA.

91.119 (b) and (c) Minimum safe altitudes: Exemption will allow the UA to fly closer to structures and persons in certain situations.

91.121 Altimeter settings: Exemption will allow the UA to use non

- standard altimeter settings for the purpose of altitude reporting.

91.151 (a)(1) Fuel requir ement s for flights in VFR conditions: Exemption allows for the use of reserve battery power rather than reserve gas.

9 1.405 (a) Maintenance required: Exemption allows for the UA to be maintained by the owner/operator.

91.407 (a)(1) O peration after maintenance: Exemption allows for the owner/operator to return the UA to flight service after

maintenance.

91.4 09 (a)(1) and (2) Inspections: Exemption allows for the owner/operator to perform all inspections.

91.417 (a)(iii) and (b) Maintenance rec ords: Exemption allows for the owner/operator to maintain and authorize all maintenance

records.

VII. Additional Information A. P2 Multirotor Pilot Operating Handbook : The POH includes: XAircraft SuperX Flight Control System User Manual V1.9

XAi rfract SuperX OSD Module User Manual

Futaba 8FG Instruction Manual

KDE Direct XF UAS ESC Series Instruction Manual Gaui 950Q Multirotor Frame Assembly Instruction Manual Aligh G3

- 5D 3 Axis Gimbal Instruction Manual

VIII. No flight privileges outside the USA are sought.

**Jonathan William Held 119 Loma Alta Drive**  **Oceanside, CA 92054 jon@p2photography.net**  **858**

**- 602** 

**- 2839**  **CFIG 3150235**