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December 31, 2015

U.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 NewJerseyAve., SE Washington, DC 20590 

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Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe FederalAviation Regulations

Dear Sir orMadam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, Wright Bros [unmanned aerial systems], seeks

an exemption from the Federal Aviation Regulations ("FARs") listed below to allow commercial operation ofits sUAS' so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required bySection 333.

The requested exemption would permit commercial operation of Wright Bros [unmanned aerial systems, a multi rotor aircraft, weighing less than 55 lbs. including cargo. The applications for this sUAS device would consist of still photographs and/or video taken by an onboard camera and associated data processingfunctions and used for aerial videographyand photographyfor weddings and special events, real estate, filmmaking and aerial inspections on construction sites of difficult to reach equipment or structures. Use of the sUAS for these purposes reduces the need to operate conventional aircraft or other equipment for the same purpose and provides veryhigh qualityimageryata fraction ofthe cost of surveys and inspections using conventional means. Likewise, inspections of structures can be safelyperformed without endangeringthe inspector or inhibiting local industrial or public operations with ladders, lifts or other equipment. These savings result in enhanced safety. efficiency and productivity for the affected activities, as well as environmental benefits and potential savings in both cost and hazardsto the public.

The name and address ofthe applicantis:

Steven L. Wright (Ref: A&P Certificate Number 3729542) DBA: Wright Bros [UnmannedAerial Videography] hereinaftercalled Wright Bros. 26920 15thAve NE Arlington, WA 98223

Phone: (424) 231-6908 Email: stevewright720@gmail.comU.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 NewJerseyAve., SE Washington, DC 20590

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### Regulationsfrom which theexemption is requested: 14C.F.R. Part21 14C.F.R. 417 (a) & (b) 14C.F.R. 45.23(b) 14 C.F.R. 409 (a) (2) 14C.F.R. 61.113 (a) & (b) 14C.F.R. 407 (a) (1) 14 C.F.R. 91.7 (a) 14C.F.R. 91.405 (a) 14C.F.R. 91.9 (b) (2) 14C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.103 14 C.F.R. 91.151 (a) 14C.F.R. 91.109 14C.F.R. 91.121 14 C.F.R. 91.119



### Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types ofsUAS' do not create a hazard to users ofthe NAS orthe public orpose a threatto national security in lightofthefollowing:

• The sUAS' size, weight, speed, and operational capability;

• Operation ofthe sUAS in close proximityto airports and populated areas; and

• Operation ofthe sUAS withinvisual line ofsight ofthe operator.



### Reform Act 333 (a) Ifthe Secretary determines that such vehicles "may operate safelyin the national airspace system, the Secretaryshall establish requirements for the safeoperation ofsuch aircraftin the national airspace system."

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft,

as the term is defined under 40101 of the Act, that includes sUAS', from the requirementthatall civil aircraftmusthave a currentairworthiness certificate.
Wright Bros. understands this provision to place the duty on the Administrator to not only process applications for exemption under section 333, but for the Administrator to craft conditions for the safe operation ofthe sUAS, ifit should be determined that the condition set forth herein do not fulfill the statutory requirements for approval.U.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 New JerseyAve., SE Washington, DC 20590

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TheAdministratormaygrantanexemption from a requirementofa regulation prescribedunder subsection (a) or (b) ofthis section orany sections 44702-44716 ofthis title iftheAdministratorfinds the exemption in thepublic interest. 49 U.S.C. 44701(f) See also 49 USC 44711(a); 49 USC 44704; 14CFR 91.203 (a) (1).

Wright Bros. will use a multiblade rotorcraft built by myself (Ref: A&P Certificate Number 3729542) weighing less than 55 lbs. including payload. It operates under normal conditions at a speed of no more than 30 knots and has the capability to hover, and move in thevertical and horizontal plane simultaneously. It will operate only in line of sight (LOS) ofthe pilot and will operate only within the project area. Such operations will insure that the sUAS will not create a hazard to users ofthe national airspace system orthe public.

Given the small size of the sUAS involved and the restricted environment withiri which it will operate, Wright Bros. falls squarely within that zone of SAFETY(an equivalent level of SAFETK) in which Congress envisioned the FAA must, by exemption, allow commercial operations of sUAS to commence immediately. Also due to the size ofthe sUAS and the restricted areas in which the relevant sUAS will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of SAFETY surrounding the proposed operations, and the significant public benefit, including enhanced SAFETY. reduction in environmental impacts, including reduced emissions associated with allowing sUAS for event and inspection operations the grant of the requested exemptions is in the public interest. Accordingly, Wright Bros. respectfully requests that the FAA grant the requested exemption without delay.

AircraftandequivalentLevel ofSAFETY Wright Bros. proposes the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of SAFETY to operations underthe currentregulatory structure because the proposed operations represent a SAFETYenhancement to the already safe photography and surveying operations conductedwith conventional aircraft.U.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 NewJerseyAve., SE Washington, DC 20590

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These limitations and conditions to which theWright Bros. agree to bebound when conductingcommercial operations underan FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 2. Flights will be operatedwithinline ofsightofa pilotand/orobserver. 3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve should that occur priorto the 20 minutelimit. 4. Flights will be operated at an altitude ofno morethan400 feet AGL. 5. Minimum crew for each operation will consist ofthe sUAS Pilot and a Visual Observer. 6. sUAS Pilot will be a skilled sUAS operator experienced in the type of UAS flown. 7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also presentthatperson can also be designated as PIC. 8. The sUAS will onlyoperatewithin a confined ProjectArea. 9. Abriefing will be conducted in regard to the planned sUAS operations prior to aerial activities. All personnel who will be performing duties within the boundaries of the SAFETY perimeter will be made aware of the sUAS flight(s). 10. The operator will obtain the consent of all persons involved in the project and ensure that only consenting persons will be allowed within 100 feet of the flight operation. 11. Pilot and observer will have been trained in operation ofsUAS generally and received up-to-date information ontheparticularsUAS to be operated. 12. Observer and pilot will at all times be able to communicate by voice andjor visuals. 13.Written and/or oral permission from the relevant property holders will be obtained. 14.All required permissions and permits to be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriategovernmental agencies. 15. Ifthe sUAS loses communications or loses its GPS signal, the sUAS will have capability to return to a pre-determined location within the Security Perimeterand land. 16.The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergenciesU.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 NewJerseyAve., SE Washington, DC 20590

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### DescriptionofSpecific Regulations:

14CFR Part21,SubpartH: Airworthiness Certificates 14C.F.R. 91.203 (a)(1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203 (a) (1). Given the size and limited operatingarea associated with the aircraft to be utilized by the Wright 

### Bros., an exemption from Part 21 Subpart H meets the requirements ofan equivalentlevel ofSAFETYunder Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C. 44701 (0) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas of the particular SUAS. Our small sUAS will be operated at low speed in a controlled environment at least five miles from an airport. An analysis ofthese criteria demonstrates thatthe SUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as 

### safe. or

### safer. than a conventional aircraft (fixed wing or helicopter) operating with an airworthiness certificate withoutthe restrictions and conditions proposed.

The sUAS to be operated hereunder is less that 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the Manual's requirements, and under the requirements and in compliance with local public SAFETYrequirements, to provide securityfor the area of operation as is currently done on active construction sites. The FAA will have advance notice ofall operations.

These SAFETY enhancements, which already apply to civil aircraft operated in connection with construction sites, provide a greaterdegree ofSAFETYto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 

### 21, Subpart H. Lastly, application ofthese

same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed ofoperation, location ofoperation, lack of explosive materials or flammable liquid fuels, and ability to carry an external load

no greaterthantwo lbs.U.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 NewJerseyAve., SE Washington, DC 20590

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### 14C.F.R. 45.23(b): Marking oftheAircraft This regulation requires certain experimental, provisionally certificated aircraft, or light sportcategoryaircraftto bemarkedwithlettersbetween 2 inches and 6 inches high "limited," "restricted," "light-sport," "experimental," or "provisional," near each
entranceto a cabin, cockpit, orpilot station.

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "experimental" can be placed. Given the size ofthe sUAS, two-inch letteringwill be impossible. The word "Experimental"will be placed onthe fuselage in compliance with 45.29 (t). The equivalent level of SAFETYwill be provided by having the sUAS marked on its fuselage as required by 45.29 (t) where the pilot, observerand others workingwith the sUAS will see the identification ofthe sUAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions Nos. 107, 8738, 10167and 10167 A.



### 14 CFR 61.113 (a) & 

### (b): Private pilot privileges and limitations: Pilot in Command Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Unlike

a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation ofthe sUAS are so diminished from thelevel of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a pilot who is an experienced sUAS operator exceeds the present level of SAFETY achieved by 14 C.F.R. 61.113 (a) &(b).



### 14C.F.R. 91.7 (a): 

### Civil aircraftairworthiness 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 for the aircraft, should this exemptionbe granted, no FAA regulatory standard will existfor determining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of SAFETYchecklists performed by myselfanA&P licensed mechanic, Ref: Certificate Number 3729542 priorto each flight, an equivalentlevel ofSAFETYwill be provided.U.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 NewJerseyAve., SE Washington, DC 20590

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14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only 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 of SAFETYwill be maintained by keeping the flight manual at the ground control pointwhere the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A 10602, 32827 and 10700.

14C.F.R. 91.103: PreflightAction This regulation requires each pilot in command take certain actions before flight to

ensure the SAFETYofflight. An exemption is needed from this requirement, as the pilot will take separate preflight actions, including checking for weather conditions, checking flight batteryrequirements, checkingtakeoffand landing distances, and all other actions in the Preflight Checklist, in the sUAS Manual. These actions will provide an equivalentlevel ofSAFETY.

14C.F.R. 91.109: FlightInstruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) thatis beingused for flight instruction unless thataircrafthas fully functioning dual controls. By design, sUAS and remotelypiloted aircraft do not have fully functional dual controls. Flight control is accomplished throughthe use of

a control box that communicates with the aircraft via radio communications. The FAA has previously approved exemptions for aircraft without fully functional dual controls. See Exemption Nos. 5778K & 9862A. The equivalent level of SAFETY provided by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS via radio signals from the controller, and by the size and speed ofthe aircraft.U.S. DepartmentofTransportation Docket Operations West Bldg Ground Floor, Room w12-140 1200NewJerseyAve., SE Washington, DC 20590

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14C.F.R. 91.119: Minimum SafeAltitudes 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 helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multirotor craft that flies similarly to a helicopter, with vertical take offand vertical landing, which will typically operate at altitudes of200 AGL an exemption maybe needed to allow such operations. The sUAS will never operate atan altitudehigherthan 400 AGL and will bein a restricted area, wherebuildings and peoplewill notbe exposed to operations without their pre-obtained consent. The equivalent level of SAFETY will be achieved given the size, weight and speed ofthe sUAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner and any onsite personnel all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far

more than the maximum 55 lbs. proposed herein and carrying flammable fuel, any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operation at or below 500 AGL in the industry. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small sUAS operations and the operations of conventional aircraft thatmustcomplywith Section 91.119.

14 C.F.R. 91.121: AltimeterSettings 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 airportor an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of SAFETYwill be achieved by the operator, pursuant to the sUAS Manual and SAFETY Checklist, confirming the altitude ofthe launch site shown on the GPS altitudeindicatorbefore flight.

14C.F.R. 91.151 (a): Fuel requirementsfor flight in VFR conditions Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS is limited to operations in sterile and controlled environments and has a limited range and flight time which require an exemption from 14 CFR 91.151(a).,, '



### U.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 New JerseyAve., 

### SE Washington, DC 20590

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The battery powering the sUAS provides approximately 20 minutes of powered flight. This does not meet the 30 minute reserve requirement in 14 CFR 91.151. Wright Bros. believes that an exemption from 14 CFR 91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small sUAS, 

### in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less that 30 minutes ofreserve fuel, does not engender the type ofrisks that Section 91.252 (a)

was intended to alleviate given the size and speed ofthe small sUAS. An equivalent level ofSAFETY

### can be achieved by limiting flight to 15 minutes, or enough battery

reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power (as determined by the onboard monitoring system and the pilot), whichever happens first. This restriction would be more than adequate to return

· the sUAS to its planned landing zone from anywhere in its limited operation area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673 and 10808.

14C.F.R. 91.203 (a) & (b): Carrying civil aircraftcertificationandregistration 

### The regulation provides in part: (a) Except as provided in 91.715, no person may operate a civil aircraft unless ithas within itthe following: (1) An appropriate and currentairworthiness certificate

... (b) No person mayoperatea civil aircraftunless the airworthiness certificate Required by paragraph (a) of this section or a special flight authorization issued under 91.715 is displayed atthe cabin or cockpit entrance so thatit is legible to passengers or crew.

The sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. Therefore there is no ability or place to carry certification and registration documents orto displaythem onthe sUAS.

An equivalent level of SAFETY

### will be achieved by keeping these documents at the ground flight control point where the pilot flying the sUAS will have immediate

access to 

### them, to the extent they are applicable to the sUAS. The FAA has issued

numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 

### 9816A and 10700.;J ' \ •

U.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 NewJerseyAve., SE Washington, DC 20590

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### 14 C.F.R 91.405 (a); 

### 407 (a)(1); 409 (a)(2); 417 (a) & 

### (b); Maintenance Inspections These regulations requirethatan aircraftoperatororowner "Shall have thataircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 of this chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given these sections and Part 43 apply onlyto aircraft with an airworthiness certificate these sections will not apply
to Wright Bros. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of SAFETY will be achieved because these small sUAS' are very limited in size and will carry a small payload and operate only in restricted areas for limited periods. If mechanical issues arise the sUAS can land immediately and will be in operation no higher than 400 feet AGL. The operator will insure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log ofany maintenance performed, (Ref: A&P Certificate Number 3729542). Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthyconditionto providethe equivalentlevel ofSAFETY.



### *********

Pursuant to 14 C.F.R. Part 11, [rule making] the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Wright Bros. seeks an exemption from the following rules: 14 C.F.R. 21, subpart H; [airworthiness certificates] 14 C.F.R. 45.23 (b); 14 C.F.R. 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) &(b); 91.405 (a)(1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmannedvehicle (55 lbs orless) in construction, inspection and events.
Approval of exemptions allowing commercial operations of sUAS in the construction, surveying, special event or inspection industry enhances SAFETY while reducing risk. Manned aircraft monitoring and surveying creates a greater risk because the craft are much larger, have combustible fuel and carry an onboard pilot. In contrast, a sUAS will carry no passengers, crew or combustible fuel and; therefore,will notexpose themto the risks associatedwith manned aircraftflights.U.S. DepartmentofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 NewJerseyAve., SE Washington, DC 20590

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The operation of small sUAS, weighting less than 55 lbs, conducted in the strict conditions outlined above, will provide an equivalent level of SAFETYsupporting the grant of the exemptions requested herein, including exempting Wright Bros. from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground and in a sterile environment and as a result, are far safer than conventional operations conducted withhelicopters operatingin close proximityto theground andpeople.

Privacy All flights will occur over private or controlled access property with the property owner's priorconsentand knowledge. Images takenwill be ofindividuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012-size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security ---provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of Wright Bros. sUAS' in special event, construction and inspectionindustrypursuanttothe sUAS Manual.

SpecificExamplesofPotential sUAS usebyWright Bros: Wright Bros. [Unmanned Aeral Videography} is currently in the process ofbuilding

a custom commercial airframe using OPEN source electronics includingAlt Hold and GPS functions to deployif/whenpermission is granted. Construction ofa similaryet

more advanced model to be introduced at a later date. Use ofthis tool would allow Wright Bros. to:

• Inspect existing inaccessible or difficult to access structures such as wind turbine towers, sides ofbridges, industrial rooftops, and smoke stacks. This would save time and money and public inconveniences bynegating the need to mobilize large lift equipment or close roads during bridge or public buildinginspections.

• Enhanced public awareness. Wright Bros. use ofaerial videography and still photography for special events and the real estate market will enable the client and those in attendance to better understand the proper and safe use ofthe sUAS venue as proposedbythe FAA.
Sincerely Steven L. Wright A&P Certificate Number 3729542

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