U.S. DepartmentofTransportation Docket Management System 1200 NewJersey Ave. SE Washington, DC 20590 

### Exemption Request Section 333 ofthe FAA Reform Act To Whom It May Concern, 11/11/2015

In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, William A Latocki, hereby applies for exemptionsfrom thefollowing Federal Aviation Regulations (FARs) in orderto operate a Small Unmanned Aircraft System (sUAS) for commercial applications in airspace that is governed by the Federal Aviation Administration {FAA). All flightoperations will be conducted underthe conditions and boundaries outlined herein oras established bythe FAA in accordance with Section 333. The exemptions, as requested by William A Latocki, would permitthe provision of commercial services to customers that are in need ofaerial data capture from asUAS. William A Latocki requests these exemptions in orderto perform commercial flights in thefollowing areas: I 1. Aerial photography and/orvideofor public and/or private use including real estate, architecture, agriculture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, and cinematography. 3. Aerial inspection/photography of residential/commercial structures under contractwiththe owners or local government authority. All flights will be conducted over private orcontrolled access propertywiththe consent and knowledge ofthe propertyowneror controlling party. All flight operations will maintain a 500 foot bufferfrom all nonparticipating persons, vessels, vehicles, and structures unless sufficient barriers are in place to protect nonparticipating persons from undue harm. Flight operations will also only be operated nearvessels, vehicles, and structures wherethe property owner/controller has granted permission and a safety assessment has been made. Regulations from which an exemption is requested: 14CFR 61.113(a) 14 CFR 91.7(a) 14 CFR 91.119(c) 14CFR 91.121 14 CFR 91.151{a) 14 CFR Subpart E(91.401- 91.417)

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### 5THE UNMANNED AIRCRAFT SYSTEM Due tothe lowcost ofoperation, increased safetyto surrounding persons and property, reduced noise and environmental impact, and theversatility ofthe sUAS platform, we believe that asUAS can be agreat solution to consumers whowould, otherwise, have to hire a larger aircraft, such as a helicopter, in orderto capture the data thatthey need. William A Latocki is seeking this exemption in orderto operate a 3DR Solo Quadcopter [2015] Manufactured by: 3D Robotics, 16084th Street, Suite 410, Berkeley, CA 94710. The 3DR Solo Quadcopter is equipped with a 3-axis gimbal and 1080p camera. 3DR safety failsafe features equipped ensuring safe operations include:
• Geo-fence capabilitythatwill limitthe height and horizontal distance thatthe 3DR Solo Quadcopter can fly from the operator. • RTL mode- In the case of low battery or lost communication between the Phantom and the operator, the 3DR Solo Quadcopterwill return tothe point oftakeoff and land itself. This mode can be manually turned on by the operator at any point in the flight. • Land mode- Loss ofGPS signal will engage land mode. The 3DR Solo Quadcopterwill land automatically at its current position if in aflight mode that requires GPS signal. • Telemetry radio communication provides real time feedback offlight data, including current altitude, latitude, altitude change rate, and GPS coordinates. Aforementioned safetyfeatures have undergone rigorous testing procedures by 3DR as well as William A Latocki. Logs and descriptions of each safetytest flight performed by William A Latocki are available upon request. These safety features combined with the PIC's knowledge obtained duringflight training

### will successfully mitigate operation safety risks.

FLIGHT OPERATIONS The operator and PIC will guarantee that operations adhere to strict standards as set below:

• The PIC must showthatthey are ableto safely operatethe UAS in a safe manner before proceeding with operations. • The UA will be operated at airspeeds below 29 knots. • The UA will be operated below400feet above ground level (AGL) at all times. • The UA will be operated within visual line ofsight (VLOS) at all times. • All operations will utilize avisual observer (VO). The UA will be operated withinthevisual line ofsight (VLOS) ofthe PIC and VO at all times. • The VO will not perform any other duties beyond assisting the PIC with seeing and avoidingtraffic and other ground based obstacles. • Proper preflight inspections will take place before each flight. • The UA may notoperate within 5 nautical miles ofan airport reference point unless a letterof agreement with that airport's management is obtained. Page 

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### of 5 FAR Section 333 Exemption Request- William A Latocki• The UA may not be operated less than 500 feet below orless than 2,000 feet horizontallyfrom a cloud orwhen visibility is less than 3 statute miles from the PIC. • The PIC must maintain a battery reserve that allows the UA to return to point of landing at normal cruise speed and land with 30% battery poWer. • The UA must remain clear ofand yield to all otherairtraffic. • Flight operations will remain 500 feetfrom all nonparticipating persons, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event ofan accident. b. All participating persons will be made aware ofthe dangers offlying a UA and the safety precautions and features that are in place. c. The aircraft is operated near vessel, vehicles, or structures where the property owner/controller has granted permission and the PIC has made a safety assessment in regard tothe close operation tothese objects. d. Operations near the PIC orVO do not present an undue hazard tothe PIC orVO per 91.119(a). • All operations will be conducted over private or controlled-access propertywith prior permission from the property owner/controller or authorized representative. By following the strict safety standards set by William A Latocki, the FAA, and the physical safety properties ofthe sUAS, will allowfor safe and efficient operations. William A Latocki hereby requests exemption underSection 333 in orderto pursue commercial sUAV applications

**wi~e** intentto provide customers withthe safest, highest quality platform available. / / Sincerelyr\ / William A La ocki 166 Orchard Street Michigan Center, Ml 49254-1227

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### EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY William A Latocki requests an exemption from the following regulations as well as any additional regulations found bythe FAA to be necessary forsafe and efficient UAS flight operations. 

### 14 CFR 61.113(a), Private pilot privileges and limitations: Pilot in command This regulation states that no person holding a private pilot certificate may act as pilot in command ofan aircraft that is carrying passengers or propertyforcompensation or hire; nor maythat person, for compensation or hire, act as pilot in command ofan aircraft. We believethat a PIC with a private pilot license has sufficientskill and knowledge to complete operations, especially after completing a sUAS knowledge and training course. We do notthinkthat a commercial pilot license will significantly improve a PIC's performance while operating a UAV. Therefore, we ask for an exemption from 14 CFR 61.113(a) in orderto operate commerciallywith the minimum ofa private pilot license. 

### 14CFR 91.7(a) Civil aircraft airworthiness As a UAS will not require an airworthiness certificate, we believe thatthis regulation is not applicable. Therefore, we request exemption from this regulation. 

### 14CFR 91.119(c) Minimum safe altitudes This regulation states that no person may operate an aircraft below 500 feet above the surface as well as within 500 feet ofany person, vessel, vehicle, orstructure. We believe that, because ofthe nature of most UAS operations, an exemption is required in orderto allow operation closerthan 500 feet tovessels, vehicles, orstructures as long as permission is grantedfrom the owning/controlling parties and an assessment is made 

### to assure that people and property are safe from undue harm. We also request that operations be allowed overcongested areas as long as the operations stay within the following standards:

• Flight operations will remain 500 feet from all nonparticipating persons, vehicles, and structures unless:
a. Barriers orstructures are present that sufficiently protect nonparticipating persons from debris in the event ofan accident. b. Participating persons are made aware ofthe dangers ofthe UAS operation and the safety precautions that have been put into place.
c. The aircraft is operated near vessel, vehicles, orstructures onlywhere the property owner/controller has granted permission and the PIC has made a safety assessment in regard tothe close operation tothese objects. d. Operations near the PIC orVO do not present an undue hazard to the PIC orVOiJer 91.119(a).
e. All operations will be conducted over private or controlled-access propertywith prior permission from the property owner/controller or authorized representative. Page 

### 4of5 FAR Section 333 Exemption Request- William A Latocki14CFR 91.121 Altimeter settings As our UAS does not utilize a standard barometric altimeter, we request exemption from 91.121 to the extent necessary to complywith applicable conditions and limitations. The altimeter reading forour UAS is calculated by GPS. The accurate and continuous readings thatwe receive from this GPS system allow us to operate our drone belowset minimums at all times. 14CFR 91.151(a) Fuel requirements forflight in VFR conditions This regulation states that no person may begin aflight in an airplane under day-VFR conditions unless there is enough fuel to flytothe first point of intended landing and, afterthat, flyfor an additional30 minutes. This regulation is intended to create a safe flying environment by creating sufficient fuel reserves. Therefore, we do not request an exemption from this regulation but, instead, request thattheterm "fuel" be changed to "battery power." We also request that our battery power reserve forour UAS operations be 30%. Our UAS has capabilities that allowthe PIC to monitor battery power levels as well as a return to land feature thatwill engage when battery levels reach a critical level, therefore returning the UAS automaticallytothe point oftakeoff. 14CFR Subpart E(91.401- 91.417)
l William A Latocki requests an exemption from the stringent maintenance regulations thatare designed to increase the safety oftheflying environment by ensuring adequate inspections and servicing ofaircraft. We are requesting exemption from these regulations because we believe that, due to the simplicity and the ease of repair, general and preventive maintenance can be performed by the PIC. The PIC is required to make a thorough preflight inspection before each operation. In the case ofa discovery offaulty equipment, most replacement and repair can simply be done on site as long as repairs are ofan airworthy manner. Major repair will still have to be performed by a licensed repair facility which will be logged in the UAS records. We believe that ourcomprehensive preflight inspection, the simplicity ofthe UAS itself, the nature ofthe UAS's operations, and thefactthat no passengers are on board the aircraft make our operations eligible forexemption from CFR Subpart E(91.401- 91.417). Thank you forthe consideration ofthese exemptions. Sincerely,

William A Latocki 166 Orchard Street Michigan Center, Ml49254-1227

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