US Department ofTransportation Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation

October6, 2015 John C. Arnold 1125 N Park Centerville, IA. 52544

U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14CFR 21 subpart H; 14CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14CFR91.9{b)(2}; 14 CFR 91.103; 14 CFR 91.109; 14CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14CFR 91.409 (a)(l) and (2}; 14 CFR 91.417(a) and (b)

Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11,John C. Arnold operator of Unmanned Aircraft Systems {UAS}, hereby applies for ·an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of designated UAS, provided such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333. Thankyou in advance foryour consideration.

### Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 1. 

### Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photographyfor public and/or private use including television, public events, cinematography and newsgathering. 

### 3. Aerial inspection/photography of residential/commercial structures undercontractwith the

owners or local government authority. 

### 4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. 

### 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

As described fully below, the requested exemption would permitthe operation ofdesignated UAS as setforth in this document under controlled conditions in the NAS that would be a)limited b) controlled c) predetermined and d) safe. Approval ofthis exemptionwould increase public awareness of UAS operations and enhance safetyto aid in fulfilling the Secretary of Transportation's (the 

### FAA Administrator's) responsibilities to "

.... establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant is: John C. Arnold Ph: 641-856-8154 Email:jjarnold@mchsi.com Address: 1125 N Park Centerville, IA 52544

### Regulationsfrom which the exemption is requested: 14CFR Part 21 subpart H 14CFR 45.23 (b) 14CFR 61.113 (a) & (b) 14CFR 91.7 (a) 14CFR 91.9 (b) (2) 14CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14CFR 91.121 14CFR 91.151 (a} 14CFR 91.203 (a) 

### & (b) 14CFR 91.405 (a} 14CFR 91.407 (a) (1) 14CFR 91.409 (a) {2) 14CFR 91.417 (a) 

### & (b) John C. Arnold will operate one or more ofthe Following model UAS: DJI Phantom 3 

### Aircraft Weight (including battery and propellers)-1280 g Diagonal size (including propellers)-590 mm Max Ascent Speed-5 m/s Max Descent Speed-3 m/s HoverAccuracy-

• Vertical:+/- 0.1 m (whenVision Positioning is active) or+/- 0.5 m •Horizontal:+/- 1.5 m MaxSpeed-16 m/s (ATTI mode, no wind)MaxAltitude Above Sea Level-6000 m OperatingTemperature-O"C- 40"C GPS Mode-GPS/GLONASS Camera Sensor-Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M} Lens-FOY 94" 20 mm (35 mm format equivalent} f/2.8, focus at 00 ISO Range-100-3200 (video) 100-1600 (photo} Shutter Speed-Ss -1/SOOOs Image MaxSize-4000 x 3000 Still Photography Modes *Single Shot * Burst Shooting: 3/5/7 shots *Auto Exposure Bracketing (AEB): 3/5 *Bracketed Frames at 0.7EV Bias *Time-lapse Video Recording Modes Phantom 3 Professional •UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

• FH D: 1920x1080p 24/25/30/ 48/50/60

• HD: 1280x720p 24/25/30/48/50/60 Phantom 3 Advanced •FHD: 1920x1080p 24/25/30/48/50/60 •HD: 1280x720p 24/25/30/48/50/60 Supported ~D Card Types* Micro SD *Max capacity: 64GB. Class 10or UHS-1 rating required Max Bitrate ofVideo Storage**Phantom 3 Professional 60 Mbps **Phantom 3 Advanced 40 Mbps Supported File Formats• FAT32/exFAT •Photo: JPEG, ONG •Video: MP4, MOV (MPEG-4 AVC/H.264) Operating Temperature-O"C- 40"C 

### Gimbal Controllable Range-Pitch -90" tp +30" Stabilization-3-axis (pitch, roll, yaw) 

### Vision Positioning MaxVelocity-Less than 8 m/s (when 2 m above ground) Altitude Range-30 cm-300 cm Operating Range-30 cm-300 em Operating Environment-Surface with clear pattern and adequate lighting (Lux> 15) 

### Remote Controller Operating Frequency-2.400 GHz-2.483 GHz Max Distance-2000m (outdoors and unobstructed) Video Output Port-USB Operating Temperature-O"C- 40"C Battery-6000 mAh LiPo 25 Mobile Device Holder-Fortablet or phone Receiver Sensitivity (1%PER)--101 dBm ±2 dBm Transmitter Power (EIRP) *FCC: 20dBm *CE: 16 dBmWorking Voltage-1.2 A@7.4 V Battery Charger Voltage-17.4 V Rated Power: Phantom 3 Professional •100W Phantom 3 Advanced •57W Intelligent Flight Battery Capacity-4480 mAh Voltage-15.2 V BatteryType-UPo 45 Energy-68 Wh NetWeight-365 g Max FlightTime-Approximately 23 minutes Operating Temperature--l0°C to 40°C Max Charging Power-100 WGiven the small size ofthe UAS in scope and the controlled environment provided, the proposed operations will adhere tothe Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surroundingthe proposed operations and the public benefit, reduction in environmental impacts, including but not limitedto reduced emissions and noise, the grantofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests thatthe FAA grantthe requested exemption. 

### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agreesto adhereto when conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1.The UAS will weigh significantly less than SS lbs. Itweighs less than 4 pounds with battery and camera. 2. The UAS, depending on the model in operation, 

### will have a maximum operating speed of

no more than SOmph. 3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). 4. Maximum flight time foreach operational flightwill be depending on the UAS model in operation, butwill not exceed 30 minutes. Flights will be terminated at 25% battery power

reserve or 30 minutes offlight time whicheveroccurs first. 5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 6. Minimum crewfor each operation will consist ofthe UAS Pilotand at least one Visual Observer (VO), and may include athird, but separate, Camera Operator (CO). 7. The UAS pilotwill be a designated Pilot in Command (PIC). The PIC will have logged a minimum of20 hours on the designated UAS.

### 8. A safety briefing will be performed priorto each day's flights consisting ofall the days' production activities. 9. All flight activities will be logged. 10. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only. 11. The flights will occur in Class Gairspace no closerthan a 5 mile radius ofthe geographic center/Airport Reference Point (ARP) ofatowercontrolled or uncontrolled airport. 12. Flights will not be closerthan a 5 mile radius ofthe geographic center/Airport. 13.The operator will file FAA Form 77111, or its equivalent, as modified in light ofthe requested exemption, with the appropriate local Flight Standards District Office (FSDO) no

more than 72 hours but no less than 48 hours from planned operation. 14. The operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100feet ofthe flight operation, and the radius may be reduced to 30feet based upon an equivalent level ofsafety determination, as U.S. DepartmentofTransportation required under the FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved. 15. The PIC and VO will have been trained in operation of UAS and receive upto date information forthe particular UAS to be operated. 16. The PIC and VO will be able to communicate byvoice and/or radio at all times. 17.Written and/orverbal permission and permits will be obtained from territorial, state, county

orcityjurisdictions, including law enforcement, fire orotherappropriate governmental agencies as appropriate toflight operations. 18. Ifthe UAS loses communications with the remote controlleror loses GPS signal, the UAS will have the capability to return to a predetermined location within a designated location and land autonomously. 19.The UAS will have the capability to abort aflight in case ofemergencies with an automated "Return Home and Land" function. 20. The UAS will have the capability to aborta flight in case of unpredicted obstacles, weather, or emergencies such as low battery.

### 14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstratesthatthe UAS operated without an airworthiness certificate in the restricted environment and underthe 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 UAS to be operated hereunder is less than SS lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials

or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threatto national security posed by the UAS, due to itssize, speed ofoperation, location ofoperation, lack ofexplosive 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 onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft orexperimental 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 morethan 6 inches high, the words"limited/' "restricted/' "light sport/' "experimental/' or "provisional/' as applicable. Even thoughthe UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance tothe cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two inch letteringwill be impossible. The word "Experimental" will be placed on thefuselage in compliance with §45.29 (f). US Department ofTransportation February 20, 2015. The equivalent level ofsafety will be provided by having the LIAS marked

on its fuselage as required by §45.29 (f) where the pilot, observer and othersworking with the UAS will see the identification ofthe LIAS as "Experimental." 14C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) 

### & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passengers or propertyfor compensation

or hire. The proposed LIAS operations may achieve an equivalent level ofsafety as achieved by current Regulations becausethe applicant's UAS do notcarry any pilots or passengers nor property.The risks attendant tothe operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14CFR 61. The PIC ofthe UAS will be, or be underthe direct supervision of, a FAA Certificated Private Pilot with currentThird Class or higher medical certificate or avalid U.S. driver's license. It is believed that the operation and limitations set forth inthe FOM will equate to the Safe operation ofthe UAS. 14 C.F.R. §91.7{a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety checklists priorto each flight, an equivalent level ofsafety will be provided. 14C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) {2) provides: No person may operate a U.S. registered civil aircraft

... (2) For which an Airplane

or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size andconfiguration has no ability or place to carry such a flight manual on the aircraft, notonly because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control point where the pilotflying the UAS will have immediate access toit. 14C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 14C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unlessthat aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, bytheir design do not have fullyfunctional dual controls. Flight control is accomplished through the use ofa control boxthat communicates with the aircraftvia radio communications. The FAA has approved exemptions for flight training withoutfullyfunctional dual controls for a number of aircraft and forflight instruction in experimental aircraft. The equivalent level ofsafety is provided bythe fact that neither a pilot nor passengers will be carried in the aircraft and bythe size and speed ofthe aircraft. 14C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicoptercomplies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption is for a LIAS that is a helicopter and the exemption requests authorityto operate at altitudes upto 400 AGL, or not

morethan 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the LIAS will never operate at higher than 400AGL with the exception that in circumstances where the UAS is used to surveyor

### photograph a structure whose height exceeds 400feet AGL, the UAS will not be operated

more than 200feet above the highest point on the structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre obtained consent. The equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owneror local officials. Because of the advance notice to the property owner and participants in thefilming activity, all affected individuals will be aware ofthe planned flight operations. Compared toflight operations with aircraft or rotorcraft weightingfar morethan the maximum SSlbs. proposed herein and the lack offlammablefuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500AGL. In addition, the lowaltitude operations ofthe UAS will ensure separation between these UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119. 14C.F.R. §91.121 AltimeterSettings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

... tothe elevation ofthe departure airport oran appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent level ofsafety will be achieved bythe operator, pursuant to the safety check list and live flight data monitoring, confirming the attitude ofthe launch site shown on the GPS altitude indicator before flight. 14C.F.R. 

### § 91.lSl(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly tothefirst point of intended landing, and, assuming normal cruising speed- (1) During the day, tofly after that for at least 30 minutes; or (2) At night, tofly afterthatfor at least45 minutes." The applicant believes that an exemption from 14CFR §91.lSl(a)falls withinthe scope of prior exemptions. Operating the UAS in atightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does not engender the typeof risks that Section 91.151{a} was intended to alleviate given the size and speed ofthe small UAS. The applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 30 minutes or25% ofbattery power- whichever happens first. This restriction would be morethan adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 14C.F.R. §91.203 (a) and (b}: Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a} Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person mayoperate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs well underthe proposed 55 lb. limit and is operated without an onboard pilot. 

### As such, there is no ability or place to carry certification and registration documents orto display them on the UAS. An equivalent level of safetywill be achieved by keeping these documents atthe ground control pointwherethe pilotflyingthe UAS will have immediate access to them, tothe extent they are applicable to the UAS. 14C.F.R. §91.405 (a}; 407 (a} (1); 409 (a) (2}; 417(a) 

### & (b): Maintenance Inspections. These regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

... ," and others shall inspect or maintain the aircraft in compliance with Part43. Given that these sections and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will notapply tothe applicant. Maintenance will be accomplished bythe operator pursuantto the flight manual and operating handbook. An equivalent level ofsafety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period oftime. Ifmechanical issues arise the UAS

can land immediatelyand 

### will be operatingfrom no higherthan 400 feet AGL. The operator

### will ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafetywill be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operatorwill ensure thatthe UAS is in working order priorto initiating flight and perform required maintenance needed. Additional Information. The applicant, John C. Arnold, believes this exemption request and associated safety considerations adequately satisfy criteria provided in Section 333 ofthe Reform Act of 2012, providing sufficientjustification forthe granting ofcommercial operations ofthe applicant's UAS. The applicant, John C. Arnold requests your respective approval ofthis Section 333 exemption petition request. Thank you for yourattention inthis matter. Please notifyJohn C. Arnold ofyouractions, and or approvals. Thank You foryour interest inthis request. Sincerely, 

# 9~e~.

John C. Arnold 1125 N Park Centerville, IA. 52544 Email: jjarnold@mchsi.com