Mitchell Meszaros 1381 Missile Base road Judsonia, Arkansas 72081

(501) 882

- 9013 mitchellmeszaros@hotmail.com U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Wa shington, DC 20590

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, I, Mitchell Meszaros , operator of Small Unmanned Aircraft System (“sUAS”) equipped to conduct aerial photography and videography, News gathering , and Aerial Surveying, hereby ap ply for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be es tablished by the FAA as required by Section 333.1 As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1)limited 2) predetermine d and 3) controlled. The proposed exemption, if granted, would allow myself to conduct commercial operations of small unmanned aircraft systems (“UAS”)

. I will meet or exceed all of the operational and safety requirements that Congress has set forth in Section 333. I ask that if any part of this request is deemed not in compliance, that part be removed and process the remaining of this request as applicable. I, furthermore, plan to exploit the capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

 Aerial surveying

 Event Photography/Videography

 News Gathering

 Agriculture purposes

 Real Estate Photography

 Aerial filmmaking and photography

 Construction site inspections and monitoring
Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b ) ( 1), Congress made it clear that Section 333 provides a mechanism for“expedited operation authorization” if several factors are met. Petitioner meets all

requirements to permit FAA approval of commercial UAS operations. Small Unmanned Aircraft Systems are oftentimes seen as superior to helicopters due to the smaller devices, cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety. I am petitioning for exemption to enable myself to operate the DJI Phantom 3 Professional equ ipped with a two

- ax is camera gimbal and using a High

- Def camera. This sUAS has a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator. They also have the failsafe function of the autopilot system which means when the communication between the Main Controller and the transmitter is disconnected i.e. lost , the outputs of all command sticks from controller will go to the center position. If GPS signal is available, the system will automatically trigger Return to Home and will land safely. Aircraft Gross weight is less than 2.8 pounds with battery and camera payload. A Pre

-flight inspection will be performed by myself in accordance with the factory instruct ion manual. An added step will be incorporated; the inspection of the propellers. A ny propeller will be replaced if it has any grooves and cracks with a manufacturers authorized propeller. The sUAS will be maintained in accordance with the manufacturer’s i nstruction manual and only manufacturer's authorized replacement parts will be used. **FCC Information** This transmitters used for controlling the sUAS complies with part 15 of the FCC rules. Operation is subject to the following two conditions: (1) This dev ice may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. The radio transmitters used for controlling the sUAS is wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitters in the 2.400GHz to 2.4835GHz frequency range.
**An tenna Separation Distance**  Wh en operating my transmitters, I will maintain a separation distance of at least 5 cm betwe en his body (excluding fingers, hands, wrists, ankles and feet) and the antenna to meet RF exposure safety requirements as determined by FCC regulations. **Pilot in Command Qualifications and Duties** I will maintain a driver’s license and I have flown over 2 0 hours of flight time, thus including takeoffs and landings within the last calendar year in the form of recreational use. I am solely responsible for the safe and efficient operation of the aircraft. Specific duties include all preflight preparation, in flight operation, post flight requirements, and all procedures including but not limited to:

 Safe in flight operations

 Pre/Post Flight inspections and upkeep

 Risk mitigation to persons and property

 Airfield Suitability**General Operating Standards**

• I will only operate the sUAS in line of sight and will operate at sites that are a 'sufficient distance' from populated areas. I will insure that the sUAS will "not create a hazard to users of the national airspace system or the public." • Before an operation of a sUAV within 5NM of an airport with a control tower, the control tower will be called to gain permission to operate the sUAS. I will give the position, altitude and the times the sUAV will be operated. The sUAS will not be operate d at an altitude of over 400 feet AGL. W eather minimums will be 3 miles visibility and a 1000 foot ceiling. Before an operation of a sUAS within 5NM of a non

-tower controlled, airport operators will be notified and I will always give the right of way to an d avoid flying in the proximity of full

- scale aircraft. At no time will the sUAV be operated within the final approach course and the takeoff course of any runway. The sUAV will not be operated at an altitude of over 400 feet AGL. W eather minimums will be 3 miles visibility and a 1000 foot ceiling.

 Maximum flight time for each operational flight will be 25 minutes

.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 25 minute limit.

 The sUAV will be programmed so that i t will be operated at an altitude of no more than 400 feet AGL.

 The sUAV operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbals).

 The sUAV will operate at speeds of no more than 25 knots, can hover, and can simultaneously move vertically and horizontally. Given the small size of the sUAV and the restricted sterile environment within which they will operate, the sUAV operations adhere to the Reform Act's safety requirements. The s UAS , powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish t he likelihood of death or serious bodily injury. W ith a small payload and maximum flight time of only 20 minutes per battery cycle, this offers little to no risk to national security. Low level oblique photos and video from several angles are far more effe ctive than ground based imagery for displaying the characteristics of large, complex properties with several buildings and large trees . The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real property as well as mitigating risk by not carrying personnel for flight operations.(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft A GL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC; (c ) All required permits will be obtained from state and local government prior to operation; **EXEMPTION REQUESTS A ND EQUIVA**  **LENT LEVEL OF SA FETY**  I, Mitchell Meszaros request an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAV System: **14 CFR Part 21, A irworthiness Certificates**  This part establishes the procedures for the issuance of a n airwo rthiness certificate. Wh ile the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, I request an experimental certificate be issued for the DJI Phanto m 3 under either or both of the following provisions: 21.191 Expe rimental certificates. Experimental certificates are issued for the following purposes: **(a) Research and development** 

. Testing new aircraft design co ncepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. **(b) Showing compliance with regulations** 

. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, fligh ts to substantiate major design changes, and flights to show compliance with the function and reliabil ity requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as we ll. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined wi th the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, tha n a conventionally certificated aircraft performing the same mission. If an experimental a irworthiness cert ificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, S ubpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph. **14 CFR 4 5.23 Display of marks; general and 45.29 Size of marks.**  These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the ent rance to the cabin, cockpit, or pilot sta tion. The sUAV does not have adequate wing space in wh ich the word "EXPERIMENTAL" can be placed, and do not have a registration number assigned to it by the FAA at this time. I, am in the process of retaining an “N

- ” registration at this time. Pending of the FAA “N” Registration, after which I will mark/identify the sUAV in the manner set forth. I do feel that the sUAV will need to belabeled on both the top side and bottom of any certain wing. As this sUAV will be in the

air (over 8ft) when in flight. **14 CFR 91.7 Prohibits the Operation of an aircraft without an airw orthiness**  **certificate** . As no such certificate will be applicable in the form contemplated by the FARs, th is Regulation is inapplicable. **14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements**

. This regulation provides that no person may operate an aircraft un less a current, approved flight manual is in the aircraft. I assume that the intent of this requi rement is to ensure that flight manual information is available to the aircrew while operating the aircraft. I reque st an exemption to this requirement since the aircraft is not only too sm all to carry documentation, th e documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propos e that a current, approved sUAS Flight Manu al must be available to myself at the ground station anyti me the aircraft is in, or preparing for, flight. **91.119 Minimum safe altitudes** : The regulation states that over sparsely populated areas the a ircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. S ince the typical m ission of the sUAS would be photography or survey of persons, vessels, veh icles or structures it would be necessary to operate closer than 500 feet to the items listed. Ope rations will only be flown over property or persons where permission has been obtain ed and careful pre

- planned flight path has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to t he small size of the UAS, the hazard to pers ons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

**CFR 91.121 A ltimeter settings** 

. The regulation requires that aircraft shall maintain cruising altitud es by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS wil l always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Le vel altimeter measurement above the takeoff poin t is transmitted via radio from the sUAS on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout. **14 CFR 91.151 Fuel requirements for flight in VFR conditions**

. The regulation provides that no person may begin a flig ht in an airplane under day

-vFR conditions unless there is enough fuel to fly to the first point of in tended landing and to fly after that for at least 30 minutes. Wefeel the intention of this pa ragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAV is b attery operated and the maximum duration of flight from a single battery charge is 15 minute s with a 25 % reserve. Since the aircraft will never fly more than 3/4 NM from the point ofintended landing, a full battery charge at launch will ensure that we meet the reserve

energy re quirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivale nt interpretation with the word "energy". **14 CFR 91.203(a) & (b) Civil aircraft: Certifications required**

. The regulation provides that an airworthiness certificate, with the registration number assig ned to the aircraft and a registration certificate must be abo ard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "di splayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maxi mum gross weight of 6.1 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this a ircraft by the FAA will be with the crew at the ground control station and available for inspe ction upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via p lacard con taining the following information plus the “N

- “ registration number to satisfy the requirement of 14 CFR 45.23. **14 CFR 91.205(a), (b), (c) Instrument and Equipment Requirements** This regulation provides a minimum set of instruments and equipment required for day and night VFR flight. Due to the small size of the sUAS it would be im possible to carry many of these instruments. 91.205 (b) 4,5,6,7,8,13,14,16,17 are not applicable as the sUAS has no Reciprocating engines or seats. 91.205 (b) 2, 3, 9 are provid ed on the hand held controller. 91.205(b) 1 is not applicable as the maximum available spe ed of the sUAS is less than the maximum required by this exemption and has no effect on performance. 91.205 (b) 10 is not applicable as the landing gear position can be verified visually before landing. 91.205 (b) 15 Due to the size it would be impossible for the sUAS to carry any known ELT. 91.205 (c) Much of this equipment is too heavy to be carried by the sUAS. W e feel that visual contact with the sUAS and indications provided via the controller that all critical information can be monitored. **14 CFR Subpart E (91.401 -**  **91.417) -**  **Maintenance, Preventive Maintenance, Al**  **terations** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 4 3. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is my intention that I will perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." I will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. M aintenance performed by myself is limited to repairing small cracks, replacing a propeller, chec king electrical connections and updating software and firmware for the on - board computer . All other main tenance will be performed by the manufacturer ortheir designated repair facility . I feel that due to the size, construction, and simplicity of

the aircraft, I can ensure an equivalent level of safety. **Safety and Benefits of the UA** **S** I will be using the UAS in a variety of applications that generally require expensive full

size manned aircraft to complete. Small, light, unmanned aerial vehicles offer countless benefits over the use of full

- sized manned aircraft for electric power line inspection, oil/gas pi peline inspection, advanced agricult ure, film and still photography; that just name s a few. Replacing significantly larger manned aircraft thus; carrying crews an d flammable fuel s. By granting myself the requested exemptions, the FAA will help drive development of safe and successful commercial UAS operations and will advance the publi c knowledge base for such operations. I am committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for futu re UAS research operations. Thus, the FAA has good cause to grant this Petition. **Conclusion** As pointed out in this application, the sUAs whi ch I would use, under authorization by the US DOT

- FAA, is a small, light

-weight device operated within the line of sig ht of the Pilot

- in

- Command , less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or oth er location with aviation activities, unless the air traffic control authorities (ATC) have been notified beforehand and have authorized each flight wi thin a radius of this distance. The sUAs have proven great capability for controlled safe flight. They are devices offered for general sale on the market around the world and have often been used as Model Aircraft in the USA. I am certain that the studies conducted until now by the FAA , about Section 332, Public Law 112

- 95, 2014, have already provided you wit h the assurances on the airworthiness of SUAs such as mine. For the foregoing reasons, the exemptions requested herein should be granted for myself, Mitchell Meszaros, and should be permitted to conduct small UAS op erations in accordance with its manuals a nd all other operating parameters deemed necessary and appropriate by the FAA. The submission of this application and its contents is the best demonstra tion that indeed it is possible to pursue the authorization process so that some SUAs may be used for le gitimate commercial activities and under reasonably safe conditions. If any indivi dual aspect of this request for exemption be unacceptable ask that it be struck alone and th e remainder of the exemption be allowed as requested.

Signed Mitchell Meszaros Owner

- Operator