Jonathan Troy Ward

FAA 3138087 license

2735 Kantian Drive

Columbus, Ohio 43219

jonathantroyward@gmail.com

Petition for exemption/rulemaking for operating UAV

I would like to seek a 333 exemption for operating a UAV under 55lbs. My intentions are to use the exemption for commercial purposes under 200 feet for aerial videography and photography. Additionally, I would like your consideration for approval outside the US for instances of international sh ots and approval to operate within and under class B and C airspaces with tower approvals. By seeking this relief, I will be able to maintain my livelihood after the surrendering of m y medical certificate due to new regulations in March of 2015. I have e xperience doing aerial photography and videography from aircraft and would eventually like to acquire several UAV’s with different characteristics under this application. I recognize that I may be limited to the blanket exemption initially with a need to further request through separate channels after this acceptance.

I believe that within this industry, trained pilots could offer vast input to the FAA for recommendations in this emerging field and I could position myself and my training background to help educate non pilot UAV operators about operations within the airspace system. Additionally, I feel (just like numerous others) that this is an emerging market where oversite is necessary and feel that I can offer a margin of safety that will benefit clien ts.

I believe that in most cases, operating a UAV (even within a 5 mile radius of a towered airport) can be safe. For the majority of the aerial photography and videography shoots can be done around 100 feet and in many cases under 50 feet (which would make it like a football being punted or a golf ball or baseball with way more control) and with an awareness of instrument approaches, basic pilot operations within these airspaces and working with airspace cont rollers, the public and businesses within these airspaces may be serviced also at an altitude that is lower than most kites. I find this especially necessary as my house falls within this limit and it is directly north of east/west runways by a few miles . This rule prevents me from even flying at low altitudes around my house below my tree line where kids are throwing objects higher than this UAV

.
Also, in some cases when I deem necessary for the video footage for a contract required and with proper plann ing on my part, allow to operate after Sunset at my discretion with proper planning and safety procedures which may consist, but not limited to the programming of the intended flight path during daylight operations to execute at night. With the capabiliti es of these drones, the autoflight modes with ability for the pilot to take over and remarkable hovering abilities

, night time operations by skilled operators will not reduce safety.

Utilizing my CFI, I would request that this waiver is for others being tr ained under my supervision and ability to release them with a minimum of 25 hours of UAV operation hours to operate under my waiver for business growth.

http://download.dji

- innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en_0915.pdf

T he DJI Phantom 3 user manual with instructions on preflight and operations is in the link above . The automatic functions manual is in development although there are wiki explanations out there for straight forward explanations to go along with the intuitive app designed for this function.

SUMMARY OF REQUEST:

Seek a “blanket” 200

- foot COA with the ability to operate inside the restricted airport areas with approval from local airspace controllers. Seek exemption to exercise this privilege outside the United States only with knowledge that ICAO and other foreig n governments may restrict operations . Additionally, the ability to fly in open International waters in case filming becomes necessary there in the future. Ability to gain approval for operating above 200 feet on a case by casebasis by communicating dir ectly with local FSDO or local airspace controllers and in the event there is no local airspace control over the intended area , the ability to fly to 400 feet.

These requests are for the ability to start up and operate a business with minimal interferenc e. In the majority of flights I will be seeking, the only one that I would like to make permanent would be the flying under the class C at KCMH to have a permanent exemption to state allowed to fly under 150 feet outside the airport boundary fences and 15 00’ north or south outside the extended centerlines of the runways. All other instances requires FSDO approval on a case by case basis . There are several building and business projects in these areas that can benefit from aerial videography services and it allows me to operate my UAV at my house approximately 3 miles north of the field at altitudes lower than a kite and in most cases

- tree lines.

Ability to fly during night when required by job and/or deemed safe by myself.

Because I will only be operatin g one UAV at a time beginning with the DJI Phantom 3, I seek that when requesting individual exemptions, it will work for any of the future drones under the 55 pound category for the time of the exemption.

I seek a civil airworthiness certificate and regis ter the DJI Phantom 3 for operation.

Sincerely,

Jonathan Troy Ward