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# UAS Exemption for DroneBuzzings LLC

AUGUST 21, 2015

US Department ofTransportation Docket Management System 1200 New Jersey Ave., SE 3 Washington DC 20590



### The name, address and contact information ofthe Petitioner is: 

### Drone Buzzings LLC Chris Pierson, Pres. 30 Pierson Ln Bernville, PA 19506 CELL PHONE: 610.207.5924 Business Phone: 484.999.0986 Email; DroneBuzzings@gmail.com 

### (1st) CPierson@DroneBuzzings.com

To whom it may concern:

Re: Exemption Request Pursuant to Public Law 112-95, Section 333 ofthe FAA Reform Act and Part 11 ofthe Code ofFederal Regulations from: 

### Regulations from which the exemotion is requested:

14 CFRPart 21 subpartH 14 CFR47.3(b)(2) 14 CFR47.31(c) 14 CFR91 .9(b)(2) 14CFR91.7 (a) 14 CFR 103 14 CFR91.109(a) 14 CFR91.131(b)(1) 14 CFR91.131(d)(1)&(2) 14**~FR** 91. 145 (b) 14 CFR91.151 (a) 14 CFR91.203(a &b)(2) 14 CFR 45.23 14 CFR61.113 (a & b) 14 CFR61.133 14 C.F.R. 91.403(b & c) 14 CFR91.405 14 CFR91.407 14 CFR91.409 14 CFR91.417 14 CFR 91.119(d)(1) 14 CFR91.121

l[Page• Note: 14 CFRPart 61 in its current form applies to mannedaircraft. 14 CFR 61.3 refers specifically toflight crew members who is defined in Part 1.1 as apilot,flight engineer, or flight navigator assigned to duty "in an aircraft" duringflight time; therefore no exemptions from Part 61.3 is beingsought for as it is notapplicable at the time of this exemption request.

Pursuant to Section 333 ofthe FAAModernization and Reform Act of2012 (the "Reform Act") and 14 CFRPart 11, Drone Buzzings LLC, operator ofa small Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits UAS, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.

The exemption would permit Drone Buzzings LLC
, to operate a small Unmanned Aircraft System (UAS) for the commercial purposes stated in Docket No.: FAA-2015-0150; Notice No. 15-01, including aerial video and photography over certain areas ofthe United States. Briefly described:


## •!• The ability to offer training to persons individually or belonging to bothprivate and/or public organizations that have interests in the use and application ofa UAS for the purpose ofthe safe operation ofa UAS to enhance the safety ofthe National Airspace System (NAS) as well as for the protection ofthe persons and property.


## •!• Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.


## •!• Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering.


## •!• Aerial inspection/photography ofresidential/commercial structures under contract with the owners or local government authority.


## •!• Aerial inspection/photography ofresidential/commercial utility infrastructure including butnot limited to electrical power lines, wind turbines and cell towers.


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

21Page· As described fully hereafter, the requested exemption would permitthe operation ofa UAS by Drone Buzzings LLC under controlled conditions in the NAS that wouldbe a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's and the FAA Administrator's responsibilities to "

....establish requirements for the safe operation ofsuch aircraft systems in the national airspace system. 

### Description and specifications ofUAS to be used by the Petitioner

DJI Phantom 3 Professional Type: Quad Rotor Copter Weight: (including battery andpropellers) 2.8 pounds Diagonal size: (includingpropellers) 23.3 inches Max Speed: 35.8 mph (no wind) GPS Mode: GPS/GLONASS Aircraft means ofpropulsion: Electric via Lithium Polymer Batteries Battery Capacity: 4480 mAh Remote Control Operating Frequency: 2.400GHz- 2.483GHz. Live Feed Frequency: 5.728GHz- 5.850GHz. Max Flight Time: Approximately 23 minutes Special Features: Return to Home (RTH) mode ifbattery life gets to low point


### DJI INSPIRE 1 T600 Type: Quad Rotor Copter Weight: (including battery andpropellers) 2935 grams (6.47 lbs) Dimensions: 438mm x 451mm x 301mm or 17.24in x 17.75in x 11.85in. Max Speed: 22.2nlsec = 49mph (no wind) GPS Mode: GPS/GLONASS Aircraft means ofpropulsion: Electric via Lithium Polymer High Voltage Batteries Battery Capacity: 4500 mAh and -+ 5700 mAh Remote Control Operating Frequency: 2.400GHz

- 2.483GHz. Live Feed Frequency: 5.728GHz- 5.850GHz. Max Flight Time: Approximately 18 minutes Special Features: Return to Home (RTH) mode ifbattery life gets to low point



### DJI SlOOO Professional Spreading Wings Type: Octo- Rotor copter Weight: (including batteryandpropellers) 4.4 Kg Diagonal size: (includingpropellers) 1045 mm Max Speed: not made for high speed GPS Mode: GPS/GLONASS Aircraft means ofpropulsion: Electric via Lithium Polymer Batteries Battery Capacity: 1 OOOmAh-2000 mAh Remote Control Operating Frequency: 2.400GHz

- 2.483GHz. Live Feed Frequency: 5.728GHz- 5.850GHz. Max Flight Time: Approximately 15 minutes
31Paoe :::;:.

### · General Operatin2 Standards

The Petitioner, Drone Buzzings LLC
, will operate the UAS in line ofsight within a predetermined area owned ami!operated by the property representative. Given the small size of the UAS andthe controlled environment provided, the proposed operations will adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations andthe public benefit, reduction in environmental impacts, includingbutnot limited to reduced emissions and noise, the grant ofthe requested exemption is inthe public interest. Accordingly the Petitioner requests that the FAA grant the requested exemption with minimum delay.

Drone Buzzings LLC will only operate its UAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure that the UAS will "not create a hazard to users ofthe national airspace system orthe public." Before an operation ofa UAS within 5NM ofan airport with a control tower, the control tower will be calledto gainpermission to operate the UAS. The PIC will give the position, altitude and the times the UAS will be operated. The UAS will notbe operated at an altitude ofover 500 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling. Before an operation ofa UAS within 5NMofa non-tower controlled, airport operators will be notified and the PIC will give the right ofway to avoid flying inthe proximity offull-scale aircraft. Atno time will the UAS be operated within the final approach course and the takeoff

course ofany runway.

- Maximumflight time for each operational flight will be 15 minutes.

- Flights will be terminated at 25%battery power reserve should that occurpriorto the 15 minute limit.

- The UAS will be programmed so that itwill notbe operated at an altitude ofno more than 500 feet AGL and not more than 200 feet above an elevatedplatform from which filming is planned.

- Minimum crew for each operation will consist ofthe UAS Pilot, andVisual Observer.

- The UAS operatedbythe petitioner weighs less than 55 pounds, includingthe payload (i.e. camera, lens, and gimbals).

- The UAS will operate at speeds ofno more than 25 knots, canhover, and can simultaneously move vertically and horizontally.

- Given the small size ofthe UAS and the restricted sterile environment within which they will operate, our UAS operations adhere to the Reform Act's safety requirements.

The UAS, poweredby batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people onboard and will thereby reduce current risk levels andthereby enhance safety and diminish the likelihood of 41Page

### .

· death or serious bodily injury. With a small payload and maximum flight time ofonly 15 minutes, this is offers little or no riskto national security.

Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics oflarge, complexproperties with several buildings and large trees.

The benefits ofreduced cost and improved quality ofpresentation from the UAwill be valuable to and benefit manybuyers and sellers ofreal property. Chartering full-sized helicopters for this purpose, have proven more costly thanmany potential clients are able to afford.
Additionally, we request that we be allowed to use our system to benefit first responders nearby who mightrequire assistance, including fire fighters, the police, the sheriff, et al., while remaining subjectto all limitations cited in this application as we do so.


### Pilot in Command and Observer Qualifications and Duties

In additionto these flight restrictions, Drone Buzzings LLC will further ensure safe operation by requiring that any PIC bethoroughly versed not only in airspace and communication issues pertainingto all aircraft operators but also in the unique aspects ofUAS flight. As set forth in the Operations Manual, Pilots will have experience not only in UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permittedto participate in commercial flights onbehalfofDrone Buzzings LLC

. Petitioner believes that this system will provide a higher level ofcompetency and proficiency for its pilots.
Pilot In Command Duties are:
The PIC is responsible for the safe and efficient operation ofthe aircraft. Specific duties include all preflight preparation, inflight operation, postflight requirements, all procedures including butnot limited to:

• Safe in-Bight operations

• RiskMitigation to Persons and Property

• Airfield Suitability

The Visual Observers Duties are:

• The Observermusthave the visual acuity to observe the UAS and be able to communicate clearly with the PIC.

• Warning the PIC ofany impending obstacles in the flight path ofthe UAS.

5\Page• Warning the PIC ofany deviations in the planned flight path ofthe UAS.

• Warning the PIC should any unauthorized personnel appear inthe area ofthe planned flight.

• The Observer will have the authority to order the PIC to terminate the flight shouldhe feel the flight cannotbe conducted safely.



### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent orhigher level ofsafety because operations will further enhance the safety ofpersons, property and also manned aircraft in the NAS. These limitations and conditions to whichthe Petitioner, hereafterreferred to as the operator, agrees to adhere to when conducting commercial operations underthe FAA issued exemption limitations, and as set forth inthe Flight Operations Manual (FOM) include:
1. The small UAS, as specifically designated and described inthis petition, will weigh less than 55 lbs includingpayload. 2. The UA will be operated within visual line ofsight (VLOS) at all times bythe operator or visual observers. (VOs). 3. The UAwill remain close enoughto the operator so that human vision unaidedby any device otherthan corrective lenses will be used. 4. The UA will notbe operated overpersons not directly involved inthe operationunless those persons remain under a covered structure. 5. The UA will only be operated during sunlight (official sunrise to sunset in operation area) unless specific authorization from the FAAis granted priorto operations. 6. The operator may use VOs for certain operations and will ensure each VO is trained on procedures listed inthe operators FOM. 7. The UAwill not be operated at a speed exceeding 87 knots (100 milesperhour) using ground speed orcalibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UAbe operated at airspeeds greater thanthe maximum UA operating airspeed recommendedby the aircraft manufacturer. 8. The UAwill be operated at an altitude ofno more than 

### 500 feet above ground level (AGL). Altitude will be measured in feet AGL. 

### Ifan objectto be inspected, such as an antenna, exceeds 

### 500 feet AGL, the operator will limitthe flight to within 

### 200 feet higherthan the structure being photographed. The operatorwill notify the FAA and local authorities ofthe proposedplanto include date, time, location and height ofthe objectto be inspectedpriorto operations. The UA will be flown in a safe manner in close proximityto the object as to not 61Pageinterfere withtraffic inthe NAS. 9. The UA will notbe operated unless visibility is greaterthan day requirements listed in 14 CFR91.155 for the Class ofairspace at the operator's ground station, on location. 10. The UA will notbe 9perated in Class A airspace 

### (18,000feet andabove). 11.The operator will receive ATC permissionpriorto operations in Class B, C, D and E airspace. 12. The operator will ensure that any VOs, ifused, will only monitor one UA at any giventime. 13.The operator will not allow operations from a moving vehicle or aircraft, except for watercraft onthe water. 14. The operator will not conduct any careless orreckless operations. A flight will be terminated immediately as possible ifthe safety ofthe operation cannot be maintained. 15. Priorto each flight, the operator will conduct a pre-flight inspection and determine thatthe UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, orequipment. Ifthe inspection reveals a conditionthat affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed, logged and the UAS is found to be in a condition for safe flight. 16.The operator will not operate any UA ifa physical ormental condition wouldpreventthe safe operation ofthat aircraft. 17.Whenusing aVO orVOs, the operator and VO mustbe able to communicate at all times. Radio communications orcommunication assisting devices may be used. Electronic messaging ortexting will not be permitted during flight operations. Daisy-chaining ofVOs for the purpose ofexpandingthe operations area will notbe permitted. 18. The operator will be responsible to see and avoid all other users ofthe NAS in which the UAS is operating. 19.The holder ofthis exemption will be responsible to ensure its aircraft are properly registered in accordance with 14 CFRPart 47, and have identification (N-Number) markings in accordance with 14 CFRPart 45 Subpart C. Markings mustbe large as practicable. 20.The UAS operator will be designated before the flight and cannot transfer his orher designation for the duration ofthe flight unless a medical duress orunforeseen emergency is preventing safe operation ofthe UAS. In which case the VO, who has been deemed qualified and trained inthe operation ofthe UAS, will operate the controls to land the UA in a predetermined "emergencyplan" set forth bythe operator who was granted this exemption. The holder ofthis exemption must ensure that VOs, ifused, canperformthe duties required ofaVO. 21.Documents for UAS operations and maintenance will be made available to the FAAupon request. Ifa discrepancy exists between the conditions and limitations inthis exemption and the procedures outlined in the FOM, the conditions and limitations herein take precedence and mustbe followed. Otherwise, the operator must follow the procedures as outlined inthe FOM. The operator may update or revise its operating documents. It is the operator's responsibility to track suchrevisions and presentrevised documents to the FAAor any law enforcement official uponrequest. Ifthe operator determines that any update orrevision

71Pagewould affect the basis upon which the FAA granted an exemption, then the operator must petition for an amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates orrevisions to the operating documents.

22. Any UAS thathas undergone maintenance or alterations that affect UAS operations or flight characteristics, e.g. replacement ofa flight critical component, mustundergo an operational check flight priorto conducting further operations under this exemption. Operational check flights may only be conductedby a qualified operator familiar with the specific UAS being checked and must remain 500 feet from any persons unless they remain under a covered structure. (NPRM wording) The operational check flight must be conducted in such a
manner so as to not pose anundue hazard to persons and property.

23.The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

24.The operator must follow the UAS manufacturer's maintenance; overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

25.The holder ofthis exemption will follow manufacturers safety bulletins for eachUAS operatedunder this exemption.

26. The holder ofthis exemption will ensure that each operator is 17 years or older, a US citizen and has a state issued driver's license.

27.The holder ofthis exemption will require that its operators demonstrate the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated inthis petition, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. Qualification flight hours and currency may be logged in a manner consistent with 14 CFR 61.51(b). Flights for the purposes oftraining the operator's and VOs (training, proficiency, and experience building) and determining the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated, will be permitted. However, training operations may onlybe conducted during dedicated training sessions. During training, proficiency, and experience-building flights will be conducted 500 feet from any persons that are not intended to be part ofsuchtraining operations unless those persons remain under a covered structure.

28. The operator will use UAS that have safety features allowing it to returnto a preset location ifit loses communications with its ground station. The operator will setthis pre-determined location within the private or controlled access property as to minimize any possible contact with objects.

8JPage29.The operator is prohibited from beginning a flight (considering windand forecast weather conditions) unless there is enough available power for the UAto conduct the intended operation and to operate afterthat with at least 25% energy reserves orwith the reserve powerrecommended by the manufacturer, whichever is greater. The operator will perform training tests, in a designated training area as prescribed herein, to assess the true energy characteristics ofthe specific UAS battery system to determine the power. Said energy tests will deem the "safety" operating procedure for actual emergencies and useful flight time.

30.The exemption holder will ensure that operators and VOs have a copy ofthis exemption, the FOM and applicable aircraft registrations located at the ground station during operations. These documents will be made available to the Administrator or any law enforcement official upon request.

31.All operations shall be conducted overprivate or controlled access property withpermission from the property owner/controller or authorized representative.

32.The exemption holder will be responsible to report to the FAA any small UAS operationthat results in: (1) any injury to a person; or (2) damage to property otherthan the small unmanned aircraft. The report would have to be made within 10 days ofthe operation that resulted in injury or damage to property. Accidents will be reported to the National Transportation Safety Board (NTSB) perinstructions contained onthe NTSB Web site: www.ntsb.gov. Current NTSB accident reporting is required when

... 1) Any person suffers death or serious injury. 2) Any UAS with max gross takeoffweight exceeding 300 pounds sustains substantial damage.
Operations for closed-set motion picture and television filming and production include the following limitations:

33.The operator must have a motion picture and television operations manual (MPTOM) in his/her possession. 34.At least 3 days before aerial filming, the operator ofthe UAS must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) withjurisdiction over the area ofproposed filming. The 3-day notification may be waived with the concurrence ofthe FSDO. The plan ofactivities must include at least the following: a.Dates and times for all flights; b. Name and phone number ofthe operator for the UAS aerial filming;

c. Name and phone number ofthe person responsible for the on-scene operation of the UAS d. Make, model, and serial orN-Number ofUAS to be used;

e. A statement that the operatorhas obtained permission from property owners and/or local officials to conductthe filming production event;

91Paoe bf. A list ofthose who gave permission, mustbe made available to the inspectorupon request; g. Signature ofoperator orrepresentative; h. A description ofthe flight activity, including maps ordiagrams ofany area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 35. Flight operations may be conducted over/nearparticipatingpersons consenting to be involved and necessary for the filming production, as specified inthe operator's MPTOM.



### Regulations from which the exemption is requested:

14 CFRPart 21, Subpart Hand 14 CFR §91.203(a)(l)&(b): Airworthiness Certificates SubpartH, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by 14 CFR91 .203(a)(1 ). Given the size and limited operating area associated withthe aircraftto be utilized bythe Petitioner, an exemption from Part 21 SubpartH meets the requirements ofan equivalent level ofsafetyunderPart 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

### (f)) and Section 333 ofthe "AReform Act both authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, andproximity to airports andpopulated areas ofthe particularUAS. in all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, inthe restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with

an airworthiness certificate withoutthe restrictions and conditions proposed.
The UAS to be operatedhereunder is less than 55 lbs. fully loaded, carries neither a pilotnor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitoredby both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree ofsafety to the public andproperty owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, SubpartH. Lastly, application ofthese same criteria demonstrates that there is no credible threatto national securityposedbythe UAS, due to its size, speed ofoperation, location of operation, nearly silent operation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load.
14 CFR47.3(b)(2) and 14 CFR47.31(c) and 14 CFR 91.203(a)(2): Registration required This regulation states inpart: Nopersonmay operate an aircraftthat is eligible for registration under 49 U.S.C. 44101- 44104 unless the aircraft is carrying aboard the temporary authorization required by §47.31(c). Part 91 .203(a)(2) reads similar. The Petitioner will be operating small

10 

### IPage· UAS. Placing registration paperwork inside the UA will be impractical. An equivalent level of safety canbe achieved bythe Petitioner ensuringthat all temporary orpermanent registration paperwork for the UAS being operated is located on site at the ground station as stated in item #30 in this document.

14 CFR 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 anAirplane orRotorcraft FlightManual is notrequired by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane orRotorcraft FlightManual, approved manual material, markings, andplacards, or any combinationthereof. The UAS, given its size and configurationhas no ability orplace to carry such a flight manual on the aircraft, not only because there is no pilot onboard, butbecause there is no room orcapacityto carry such

an item onthe aircraft. The equivalent level ofsafety will be maintained by keeping the UAS flight manual atthe ground station where the UAS operator will have immediate access to it.

14 CFR91.109(a): Flight Instruction Section 91.109(a) provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The Petitionerwill be operating small UAS that it do not have fully functional dual controls. Flight control is accomplished through the use ofa control boxtransmitter that communicates withthe aircraft viaradio communications. The equivalent level ofsafety is provided bythe fact that neither a pilotnorpassengers will be carried in the aircraft and by the size and speed ofthe aircraft. Flight instruction is accomplishedby handingthe transmitter betweenthe instructor and trainee orby the use ofa buddy box system instruction will also be accomplished in accordance with item #27 inthis document.

14 CFR91.119(d)(l): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91 .119(d)(l) allows helicopters to be operated at less than the minimums prescribed, providedthe person operatingthe helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is similarto a helicopter and the exemption requests authority to operate at altitudes up to 500 AGL, or notmore than 200 above a structure from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 500 AGL with the exceptionthat in circumstances where the UAS is used to survey orphotograph a structure whose height exceeds 500 feet AGL, the UAS will notbe operated more than 200 feet above the highest point onthe structure in accordance with procedures outlined in item #8 ofthis document.

The equivalent level ofsafety will be achieved giventhe size, weight, speed ofthe UAS as well

as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants inthe filming activity, all affected individuals will be aware ofthe planned flight lliPage· operations. Compared to flight operations with aircraft orrotorcraft weighting far more thanthe maximum 55lbs. proposed herein and the lack offlammable fuel, noise and any risk associated with these operations is far less than those presently presented with conventional aircraft operating at orbelow 500 AGL. In addition, the low-altitude operations of the UAS will ensure separation between these UAS operations and the operations ofconventional aircraft that must; comply with Section 91 .119. The procedures outlined inthis document prohibit flight over persons not involved in operations unless they remain under a covered structure.
14 CFR 91.121: Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the small UAS does not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuantto the safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown onthe GPS altitude indicator before flight. Flights will be conducted 500 feet above that read out orwithin 200 feet above the highest point ofthe structure being filmed as outlined in item #8 ofthis document

14 CFR45.23: Marking ofthe Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed

on limited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operatormust also display onthat aircraft near each entrance to the cabin, cockpit,

or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Eventhough the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit orpilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental

14 CFR 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 for the aircraft

an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including butnot limited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation of flight. Before the aircrafttakes flight, a home GPS location will be set for any reason the aircraft becomes disoriented in flight, and return safely to home.

121 Page

### · 14 CFR91.145: Management ofaircraft operations in the vicinity ofaerial demonstrations and managing events states: ofthis section, the FAA considers the following factors: (1) Area where the event will be held. (2) Effectflight restrictions will have onknown aircraft operations. (3) Any existing ATC airspace traffic managementrestrictions. (4) Estimated duration ofthe event. (5) Degree ofpublic interest. (6) Number ofspectators. (7) Provisions for spectator safety. (8) Number and types ofparticipating aircraft. (9) Use ofmixed high and lowperformance aircraft. (10) Impact on non-participating aircraft. (11) Weather minimums. (12) Emergency procedures that will be in effect. Note: If

### Drone Buzzings LLC intends to use a UAS to cover sporting events from outside the activity, coordination will be completed by contacting the FSDO priorto the eventto ascertain the presence ofany otherunmanned activities. Flight activity will be conductedbased on safety and withparticular attention to the avoidance ofoverflight oflarge concentrations ofpeople. However, specific relieffrom this regulation is still necessary to ensure compliance with FARs.



### 14 CFR 61.113 (a) and (b): Private Pilot Privileges and 

### Limitations and 61.133 Commercial pilot privile&es and limitations.

Pilot in Command. Pursuant to 14 CFR61.113 (a) & (b), no person who holds a private pilot certificate may act as
a pilot in command ofan aircraft that is carrying passengers orproperty for compensation or hire. 

### Drone Buzzings LLC may achieve an equivalent level ofsafety as achieved by current Regulations because the applicant's UAS do not carry any pilots orpassengers norproperty. The risks inherent to the operation ofUAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61.


### Drone Buzzings LLC seeks exemption from 14 CFR 

### § 61.113, whichrestricts private pilot certificate holders from flying aircraft for compensation orhire, and would also require a second class medical certificate. Thepurpose ofPart 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications ifthe private pilot is carryingpassengers or cargo for hire. Inthis case, while the UASs will be operated as part ofa commercial operation, it carries neither passengers nor cargo. Inthe Grant ofExemption in FAADocketNo. FAA-2014-03 52, the FAA determined that the unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the additional cost and restrictions encumbent withrequiring the PIC to have a commercial pilot certificate and/or class II medical certificate.

131Page· The restrictions 

### Drone Buzzings LLC has placed on its UAS flight operations manual is to meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA DocketNo. FAA2014-0352. 

### Drone Buzzings LLC will operate away from persons and property not involved in the operation, and flights will be conducted using VLOS at 500' AGL orbelow. A NOT AM will be issued between 48 and 72 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO.


### 14 CFR 91.131 (b)(l): Pilot requirements for Class B airspace This regulation states that no person may operate a civil aircraft within a Class B airspace unless thatperson is a private pilot, recreational pilot, sport pilot or is a student pilotthat meets requirements of§61.94 or §61.95 ofthis chapter. An exemption from this regulation may be required. An equivalent level ofsafety will be achieved by operating the small UAS at altitudes listed in the limitation section ofthis document. The UA will not be landing or departing from airports in Class B airspace nor flying through Class B airspace. The UAS will be flown in a controlled environment within VLOS. The UAS operator will require ATC permission priorto conducting operations and will give right ofway to any manned aircraft.



### 14 CFR 91 .131(d)(l) and (2): Equipment reguirements for Class B airspace The regulation states that no person may operate an aircraft in Class B airspace unless it is equipped with a transponder and after January 1, 2020 an ADS-Bout system. An exemption may be required. Due to the size, weight and payload capacity ofthe small UAS, installing these systems is notpractical. An equivalent level ofsafety will be achieved by operating the small UAS at altitudes listed in the limitations section ofthis document. The UAS will not be landing or departing from airports in Class B airspace nor flying through Class B airspace. The UAS will be flown in a controlled environment within VLOS. The UAS operator will require ATC permission priorto conducting operations and will give right ofway to any manned aircraft. Note: If

### Drone Buzzings LLC is conducting an exposition or contracted for filming purposes at an airport that would require landing or departing in Class B airspace. 

### DroneBuzzings LLC will seek and acquire the properpermits thru the FAA, local authorities, and any other necessary agency. A detailed proposed plan would include date, time, location and purpose of needed area to complete the planned operations. The UA will be flown in a safe manner as to not interfere with traffic in the NAS.



### 14 CFR 91.403 (b) and (c); 91.405; 91.407; 91.409; 91.417: Maintenance and Inspections. These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in accordance with Part 43. Part 43 only applies to aircraft with a US airworthiness certificate or foreign registered aircraft operating in common carriage under provisions ofPart 121 or 135. These sections will not apply to the Petitioner who will be operating a small UAS. An equivalent level ofsafety will be
141 Page· achieved as the UAS will be maintained in accordance withthe UAS manufacturer's instructions and limitations listed inthe operator's FOM. The small UAS will carry a small payload and operate in a controlled area for a limitedperiod oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higherthan 500 feet AGL, withoutpriorFAA authorization. The operator will ensure thatthe UAS is in working order priorto initiating flight, perform required andpreventative maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar withthe aircraft and best suitedto maintain the aircraft in an airworthy conditionto provide the equivalent level of safety.

14 CFR 91.151: Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane under VFR conditions unless (considering windand forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed. (1) Duringthe day, to fly after that for at least 30 minutes; or (2) Atnight, to fly afterthat for at least45 minutes."

The batterypoweringthe UAS provides approximately 30 minutes ofpowered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limitedto approximately 10 minutes in length. Given the limitations onthe UAS'sproposedflight area and the location ofits proposed operations within a predetermined area, a longertime frame for flight in daylight ortwilight VFR conditions is reasonable.
Applicant believes that an exemption from 14 CFR §91.151(a) falls withinthe scope ofprior exemptions. Operating the UAS, in a tightly controlled area where onlypeople andproperty
owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engenderthe type ofrisks that Section 91 .151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted.
Applicant believes that an equivalent level ofsafety canbe achieved by limiting flights to 30 minutes or25% ofbattery powerwhicheverhappens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating

area.

14 CFR91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulationprovides in pertinentpart: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless ithas within it the following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate 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.
151Page· The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability orplace to carry certification and registration documents orto display them on the UAS.

An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. Again, ifpilot forgets documents, all documents can be achieved via the DJI Pilot App.

14 CFR 91.403(b) and (c); 91.405; 91.407; 91.409; 91.417: Maintenance and Inspections. These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect ormaintain the aircraft in accordance with Part 43. Part 43 only applies to aircraft with a US airworthiness certificate or foreign registered aircraft operating in common carriage underprovisions ofPart 121 or 135. These sections will not apply to the Petitioner who will be operating a small UAS. An equivalent level ofsafety will be achieved as the UAS will be maintained in accordance with the UAS manufacturer's instructions and limitations listed in the operator's FOM. The small UAS will carry a small payload and operate in a controlled area for a limitedperiod oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than 500 feet AGL, without priorFAA authorization. The operator will ensure that the UAS is in working order priorto initiating flight, perform required and preventative 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 of safety.

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## .,

.. Safety and Benefits ofthe UAS

Drone Buzzings LLC will be using the UAS in a variety ofapplications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer a myriad benefits overthe use offull-sized manned aircraft for electric powerline inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography,justto name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers orcrew creates a much greater margin ofsafety for the pilots and

crew. Bygranting Drone Buzzings LLC 'srequested exemptions, the FAAwill help drive development ofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations. Drone Buzzings LLC is committed to promotingthe UAS research efforts ofpolicymakers including the FAA, NASA, DOD andDARPAby sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAAhas good cause to grant this Petition.



### Conclusion As pointed out inthis application, all the SUAs which Drone Buzzings LLC use, under authorization bythe US DOT-FAA, are small, light-weight devices operated withinthe line of sight ofthe Pilot-in-Command (PIC), less than 500 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, Spaceport, or other location with aviation activities, unless the airtraffic control authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance.
All our SUAs have proven capability for controlled flight. They are devices offered for general sale onthe market around the world and have oftenbeen used as Model Aircraft inthe USA. We are certainthat the studies conducted until nowbythe FAA, about Section 332, Public Law 112-95,2014,have already providedyou with the assurances onthe airworthiness ofSUAs such as ours.

Forthe foregoing reasons, the exemptions requested herein shouldbe granted and Drone Buzzings LLC should be permittedto conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate bythe FAA. The submission ofthis application and its contents is the best demonstration that indeed it is possible to pursuethe authorizationprocess so that some SUAs may be used for legitimate commercial activities and underreasonably safe conditions.

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Additional Information

The Petitioner, ChristopherPierson, president ofDrone Buzzings LLC, currently holds certification by the state ofPennsylvania for inspection ofAmusements and Amusement rides, and therefore is quite knowledgeable about Saftey, Risk Assessment, and Protection to property and human lives from defective ordysfunctional equipment. His expertise ofsafety in the amusement industry would be helpful and translate into teaching others about UAS safety and operations to generations to come.

He has had a long term love for RC devices since he was a young boy and therefore possess RC skills such as model building, repairing, maintaining and flying experience. He also holds a Bachelor ofRecreation Management degree from Brigham Young University in Provo UT and is currently the General Manager ofa 10 acre multi-attraction Entertainment facility in Leesport, PA.

Satisfaction ofcriteriaprovided in Section 333 ofthe Reform Act of2012 provide more than adequatejustification for the grant ofthe requested exemptions allowing the commercial operation ofthe Petitioner's UAS.
Respectfully submitted,

ChristopherPierson, President Drone Buzzings LLC DroneBuzzin s.com

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