Bryan Pearson

223 Kirkwood Rd. NE Atlanta, GA 30317 ( 404 ) 729

- 5062 brypearson@gmail.com

Petition for Exemption

Federal Aviation Administration

Re: Unmanned Aircraft System use in NAS for compensation

Petitioner, Bryan Pearson . (“ Mr. Pearson ”) , her eby petitions the Federal Aviation Administration ( “ FAA ” ) for an exemption from Part 21; §§ 45.23(b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, if granted, would allow operation of unmanned aircraft sy stems (UAS) for the purpose residential and commercial real estate, as well as artistic still photography

.

Petiti oner hereby proposes the following terms and conditions for the grant of the exemption requested herein:

The UAS proposed by the petitioner , the DJI Inspire 1 is a n unmanned four

- rotor, four

motor “quadcopter” manufactured by DJI. The UA S is under 4 5 po unds , wi ll be flown at all

times under 3 00 feet AGL as measured by the UA S’ on

- board GPS system

, will be kept within line of sight of the Pilot in Command (“PIC”) , will have a separate safety Visual O bserver (“VO”) at all times in communication with and wi thin 5 feet of the PIC, will be flown at all times at speeds of 20 miles per hour or less

, will be flown at all times during daylight hours , always using Visual Flight Rules (“VFR”) and within visual line of sight (“VLOS”)

, and never using first person vi ew by the PIC . The PIC will be able to use human vision unaided by any device other than corrective lenses as specified by a cu rrent state

- issued driver ’ s license

. Each PIC will

have over 100 hours of logged flight experience in the same UAS type or model , including 10 take offs and landings within the prior 30 days . The PIC will conduct a f ull and complete inspection of aircraft prior to the initial takeoff of each flight.

A precedent has been set for this type of commercial use with this exact type of

UAS. See: Exemption No. 11428, Regulatory Docket No. FAA

– 2015

– 0172.

Public Benefit

Regular helicopters are, except as provided in Section 91.119, not allowed to fly less than

500 feet AGL. UAS on the other hand are best when flown between 50 and 300 f eet AGL and in fact the best video quality is 50 to 100 feet. A large manned helicopter could also cause veryserious damage to persons or property on the ground and even to pilots and passengers inside a manned helicopter. A UAS weighing in at approxima tely six pounds would not be nearly as hazardous. Additionally, a regular helicopter is normally larger than a standard automobile whereas the UAS is smaller than a basketball. It is substantially safer for the public to have a UAS accomplish the job of aerial photography than a manned helicopter just based on size alone.

In addition, the UAS can be operated for substantially less costs than a regular manned helicopter. The public is significantly served by reducing the cost of videography via UAS

airc raft.

Proposed Operational Parameters

The PIC will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements will be established and identified in the operator’s manual. At a minimum, the following w ill be included in the operator’s manual:

1. Actuators / Servos

2. Transmission (single rotor)

3. Powerplant (motors)

4. Propellers

5. Elec tronic speed controller

6. Batteries

7. Mechanical dynamic components (single rotor)

8. Remote command and control

9. Ground control station (if used)

10. Any other components as determined by the operator

Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft

will be prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condi tion for safe flight. The Ground Control Station, if utilized, will be included in the preflight inspection. All maintenance and alterations will be properly documented

in the aircraft records.

Any UAS that has undergone maintenance or alterations that a ffect the UAS oper ation or flight characteristics ( e.g. replacement of a flight critical component) will undergo a functional test flight in accordance with the operator’s manual. The PIC who conducts the functional test flight will make an entry in the UA S aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operator’s

manual.

Prior to operations conducted for the purpose of capturing video, the PIC must have

accumulat ed and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of five

hours as a UAS pilot operating the make and model of UAS to be utilized for operations underthe exemption and three take

- offs and three landings in the preceding 90 days. Tra ining, proficiency, experience

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience

- building, and take

- off an d landing currency flights all persons not essential for flight operations are considered non

- participants, and the PIC must operate the UA with appropriate distance from non

- participants in accordance with 14 CFR § 91.119.

Prior to operations conducte d for the purpose of capturing video (or similar operations), a flight demonstration, administer ed by an operator

- approved and qualified pilot must be successfully completed and documented. This documentation must be available for review upon request by th e Administrator. Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examin ers, the petitioner will conduct these tests in accordance with the operator’s manual.

The UAS will not be operated directly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or proper ty on the surface in the event of a UAS failure or emergency.

Regarding distance from non

- participating persons, the operator will ensure that no persons are allowed within 200 feet of the area except those consenting to b e involved and necessary for ca pturing video . This provision may be reduced to no less than 100 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector’s evaluation o f the video production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers
may protect non

- participating persons ( e.g. observers, the public, news media ) from debris in the

event of an accident. This is also consiste nt with the Order

.

If the UAS loses communications or loses its GPS signal, the UA S must return to a pre

determined location within the security perimeter and land or be recovered in accordance with the operator’s manual. The proposed UAS, the DJI Inspi re 1, is designed to increase altitude 20 meters or 60 feet upon loss of signal between the ground controller held by the pilot and the aircraft itself. Upon reaching the higher altitude (a safety feature to avoid people, trees and buildings), the UAS will return to its original take

- off point of origin and slowly land. It is critically important for the pilot to calibrate the aircraft prior to its flight. The calibration procedure sets the compass and lets the aircrafts onboard computer know where it is lo cated on

E arth. The UAS also has a F lytrex black box system installed which tracks every flight so if a loss of link to the aircraft from the controller ever occurs, then the pilot can follow and retrieve

the UAS when it lands. Additional details concerni ng lost

- link failsafes can be found in the Operator’s Manual.

The PIC will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual.

Each UAS operation must be completed within 30 minutes flight time or with 25% battery power remaining, whichever occurs first.The PIC will request a Notice to Airmen (“NOTAM”) not more than 72 and not less than 48 hours prior to the operation.

The operator will develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures will be added to the operator’s

manual.

Each UAS operated under this exemption will comply with all manufacturer Safety

Bulletins.

The operator must develop UAS technician qualification criteria. These criteria must be added to the operator’s manual.

The preflight inspection section in the operator’s manual must be amended to include t he following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual.

Before conducting operations, the radio frequency spectrum used for operation and

control of the UA S must comply with the Federal Communications Commission ( “ FCC ” ) or other appropriate government oversight agency requirements.

The documents required under 14 CFR § 91.9 and § 91.203 will be available to the PIC at the ground control station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

The UA S will remain clear and yield the right o f way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

UAS operations will not be conducted during night, as defined in 14 CF R § 1.1. All operations will be conducted under visual meteorological conditions ( “ VMC ” ). Flights under special visual flight rules ( “ SVFR ” ) are not authorized.

The UAS will be operated by the PIC from any moving device or vehicle.

The UA will not be o perated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

The UA will not operate in Class B, C, or D airspace without written approval from the

FAA. The UA will not o perate within 5 nautical miles of the geographic center of a non

- towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with aNOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical

b oundaries of the operational area as defined by the applicable COA must be reported to the

FAA UAS Integration Office (AFS

- 80) within 24 hours. Such a ccidents must be reported to the National Transportation Safety Board ( “ NTSB ” ) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and authorization to resume operations is provided.

Unless otherwise specified in this grant of exempt ion, the UAS, PIC, and operator must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

The Federal Aviation Administration by and through its authorized representative is requested to approve this petition based on the above terms and conditions for a certificate of authority and certificate of exemption to operate within the above parameters for compensation or hire within the United States National Air Space.

Respectfully submitted:

Bryan Pearson Atlanta, Georgia