Timothy Dacey 430 S. 166th Ave Goodyear, AZ 85338 636
- 357
- 7864 timdaceyaz@gmail.com July 9 , 2015 Docket Management Facility U.S. Department of Transportation 1200 New Jersey

Avenue, SE West Building, Ground Floor Room W12

- 140 Washington, D.C. 20590 Dear Exemption Manager: **Introduction** I am subm itting my

petition for exemption fro m the Title 14 Code of Fe deral Regulation sections listed below in order to commerciall y operate small Unmanned Aircraft and S ys tems (UAS) pursuant to section 333 of the FAA Modern ization and Reform act of 2012. All flights will be flown by a PIC who holds an FAA Private Pilot Certificate. UAS to be flown will be the DJ I Phantom 3 and DJIInspire 1 series platforms. Specific proposed limitations and conditions of flight will be outlined below. Safety of flight is the top priority

and all aspects of training, UAS maintenance, communications, and pre

- flight planning , flight execution will be strictly enforced.

14 CFR 45.23 (b) 14 CFR 61.113 (a) (b) 14 CFR 91.7 14 CFR 91.9 (b) (2) 14 CFR 91.103 (1) 14 CFR 91.119 14 C FR 91.121 14 CFR 91.151 (a) 1 4 CFR 91.203 (a) (b) 14 CFR 91.405 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) (b)This exemption w ill allow Timothy Dacey to operate an Unmanned Aircraft System

(UAS) for the commercial purpose of conducting line of sight aerial video graph y and photography including , but not limited to the following:

 Inspections of construction Sites and utility company infrastructure s  Agriculture  Real Estate  Sporting Events, Golf courses  Search and rescue  Roof and Solar panel inspections **Suggested Public Federal Registry** The petitioner is seeking an exemption to operate an unmanned aircraft s ys tem (UAS) Under the new FAA “Summary Grant” approach announced April 15, 2015
. It is my understanding that the FAA will still review each section 333 petition individually , however, I am hoping that the agency will accept my

particular petition and include it in the next summary

gr ant and issue me an ex emption based on the presumption that the FAA has already granted a pr evious exemption similar request. **Petitioner Background** My name is Timothy

Dacey . I am the holder of Private Pilot Certificate # 2072283 and Groun d Instructor Certificate (Advanced and Instrument) #498588015. With my clear understanding of the FAA rules and regulations, awareness of airport operations, the national airspace s ys tem, restricted airspace , MOA’s, Prohibited areas and TFR’s , I possesses the aeronautical knowledge required to safel y operate UAS aircraft within the United States airspace sy stem.
**Public Interest** The public interest will be served b y granting Timothy Dacey a petition for exemption. Timothy Dacey will be incorporating the DJ I series of UAS Quadcopters for use in video graph y and photography services to clients. Flight using the DJ I series of Quadcopters have identifiable safety benefits that include reducing the costs, dangers and emissions associated with flying full size helicopters and fixed wing aircraft for video graph y and photography purposes . UAS platforms carry no fuel to ignite or explode, no airborne crew members, are cheaper to operate and add a greater degree of f

lexibility
. The use of UAS platforms to perform th is ty pe of work will greatl y reduce adherent risks to crew members of helicopters and fixed wing aircraft from engine failure, fire and mechanical issues. Zero fuel will be used as UAS are battery operated. The public will be better served as there are als o no environmental concerns.**Proposed limitations and conditions of UAS flights**

 The UAS will weigh less than 10 lbs.  Flights will be operated within visual line of sight of the pilot and spotter  Flights will be operated at an altitude of no more than 400 feet AGL, although most flights will be between 50

- 100 feet AGL.  Maximum total flight time for each flight will be 20 minutes. Flights will be terminated at 25% of battery reserve should that occur before 20 minute limit.  Minimum two (2) man crew for each operation consists of the Pilot in Command (PI C) and spotter
.  The UAS Pilot in Command will be an FAA licensed airman with a Private Pilot certificate and third class medical or valid state driver’s license.  The UAS will not enter any MOA, Restricted airs pace or TFR as outlined by the FAA.  A pre
- flight briefing will be conducted in regard to the planned operation prior to each flight activity
.  Written or oral permission will be obtained from the relevant property o wners prior to flight.  If the UAS loses co mmunications or GPS signal, the UAS will have the capability to return to a pre - determined location and land  The UAS will have the capability to abort any

flight in case of unpredicted obstacles or emergencies. **Equipment and Operational Capability**  I am planning on using the DJ I Phantom 3 Professional and DJ I Inspire 1 series UAS Quadcopter platform s . The following are some of the features. 1) Very lightweight with t akeoff weight s of less than 7 pounds 2) Flight times between 18

- 22 minutes. 25% battery remaini ng alert. 3) The DJIs eries of quadcopters are battery p owered only

and do not carry any

fuel or propellant. 4) The DJ I series of quadcopters have an integrated GPS system that calculates the UAS’s position and height and relay s that information to the operator
. 5) The DJ I series of quadcopters contain a failsafe mode that if its connection to the remote controller is lost, the sy stem permits the UAS to return to a predetermined location and land without damage or injury to others. 6) State of the art electronics, cam eras, controllers, and fail safe features.**Specific Sections Seeking Exemption**

**14 CFR 45.23 b** The regulation requires an N number and other specific markings from 2” to 6” on experimental or provisional aircraft. An exemption is requested from this section. Even though the UAS will have no airworthiness certificate and is very small (less than 10 lbs. ) We will mark in letters “experimental” of the appropriate size for the UAS. **14 CFR 91.9 (b) (2)** This section calls for a civil aircraft flight manual, markings and placards to be available in the aircraft. An exemption is requested for this section. The UAS given its size and configuration has no ability to carry a flight manual on the aircraft. We will maintain the equivalent level of safety by keeping the operating manual on site and available to the PIC at any time during the UAS operation. **14 CF R**  **91.103** S ection (1) of pre

- flight action calls for an approved flight manual to be available. An exemption is requested. As there in no approved flight manual on board, reference will be made to the UAS operating manual and we will maintain the required level of safety.

**14 CFR 61.113 a & b** These regulations limit Private Pilots to non

–commercial operations. Because the UAS will not carry

a pilot or passengers and will be operated within limited areas and altitudes, the proposed operation can achieve a level of safety of current operations requiring the PI C operating the aircraft to have a Private License rather than a commercial license to operate this small UAS. **14 CFR 91.7 a** While the UAS platform will not have an airworthiness certificate, the airworthy condition of the UAS will be the responsibility of PIC. **14 CFR 91.119 c** This regulation establishes safe altitudes for operation of civil aircraft over areas other than congested areas . Timothy Dacey requests relief from this section with respec t to persons involved as well as vehicles and structures. The UAS will not be operated above 400 feet AGL. It will be operated in defined areas where people, building and structures will not be exposed to operations without their written or oral consent.**14 CFR 91.121**

This regulation requires each person operating an aircraft to maintain a cruising altitude by reference to an altimeter that is set to the elevation pf the departure airport or an appropriate altimeter setting available before departure. As the UAS does no t have a barometric altimeter and exemption is requested. The UAS platform flight controller utilizes GPS equipment to determine and maintain altitude. The GPS is displayed on the operator video screen and provides sufficient information for the PI C to mai ntain altitude s at or below the 400 feet AGL limitation. **14 CFR 91.151 a** This regulation prohibits an individual from beginning a flight in an airplane under VFR conditions unless there is enough fuel on board to fly to the first point of intended landin g, and assuming normal cruise speed fl y an additional 30 minutes during the day and 45 minutes at night. Since the UAS carries no fuel and approximately 20 minutes of battery

power, an exemption is requested. The UAS flight is alway s conducted within line of sight and will terminate the operation when the battery reaches 25% remaining power.
**14 CFR 91.405 a 14 CFR 91.407 a (1)**  **14 CFR 91.409 a (1) & (2) 14 CFR 91.417 a & b** 
The above regulations require that an aircraft owner or operator “shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except provided in paragraph (c) of this section have discrepancies repaired as presc ribed in part 43 of this chapter. The above sections and part 43 appl y to aircraft that possess an airworthiness certificate and these sections will not apply to UAS operations. An exemption is requested from this section. All maintenance will be performe d by the operator per the maintenance manuals and recommendations by DJIwhich is the manufacturer of the UAS platform to be used. An equivalent level of safety will be accomplished by pre and post flight inspections. Any discrepancy

or concern will be addressed and the flight canceled or discontinued.**Conclusion**

This petition for exemption satisfies the criteria articulated in section 333 of the Reform Act of 2012 including UAS weight, speed, operating capabilities, proximity t o airports and populated areas, operations by line of sight, safety and pilot qualifications. Granting this extension will benefit the public interest as a whole including increased safety, reducing risk by

removi ng human exposure to danger, no environmental impact, improved customer services and cost savings. Sincerel y, Timothy Dacey