### W. DAN PETERS October 5, 2015 2819 144th Street Court East Tacoma, Wa 98445 (cell) 206-310-5808 (home) (253) 538-6888 Email: wdanpeters@jcloud.com



### U. S. DepartmentofTransportation Docket Management System 1200 NewJerseyAvenue, SE Washington DC, 20590
.E.xerpp_tion Request Sectiqn 33.3 ofthe ReformActof2012

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References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter ofthe petition of DOUGLAS TRUDEAU



### Dear Sirof Madam,2) FAA Exemption No.11136, Regulatory Docket No. FAA-2014-0508 in the matter ofthe petition ofADVANCED AVIATION SOLUTIONS, LLC 3) FAA Exemption No.11080 Regulatory Docket No. FAA2014-0355 in the matter ofthe petition of FLYING CAM INC

In accordance with the FAAsGuidelinesfor Submitting a Petition for Exemption under section 333 ofthe FAA Modernization and ReformActof2012, I, W. DAN PETERS, referred to hearafter asthe petitioner, requests exemption from thefollowing sections oflitle 14, Code of Federal Regulations 

### 61.113{a}; 61.113 {b); 91.119{c}; 91.121;91.151{a}; 91.405{a}; 91.407{a}{1}; 91.409{a}{1); 91.409{a}{2}; 91.417{a}&{b} in orderto operate small unmanned aircraftsystems (UAS} commercially in airspace regulated bythe FederalAviation Administration (FAA) forthe purpose of aerial photography,



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### 6cinematography, videography, mapping, crop surveying, inspection and other flight operations that could be performed safely and more cost effectivelywith the use ofsmall UAS at low altitude within U.S. national airspace system as compared 

### to manned aircraft. Operations will be performed only atthe request of and with authorization and permission of clients ortheir authorized agents in orderto facilitate commerce and raise awareness ofthe beneficial uses ofsmall unmanned airsystems. So long assuch operations are conducted within and under the conditions outlined herein or as may

### be established bythe FAA as required by Section 

### 333. The conditions identified and proposed bythe petitioner are drawn from references 

### 1-3.

The EARs

The petitioner seeks exemption from the above mentioned FARs forthe following reasons:


### 61.113(a) & 

### (b); The petitioner requests relief in orderto facilitate the utilization of pilots who hold a PRIVATE PILOT (or greater) .certificate. Any pilots operating underthis exemption would be required to comply with any condition as setforth and in a similar fashion to the previously granted**.exemption~**.. 

### 91.119(c) As discussed in Exemption 

### 11138 (DOUGLAS TRUDEAU), operations conducted closerthan 

### 500feet to the ground may require thatthe UA

### be operated closerthan 

### 500 feet to essential persons, orobjectsthatwould not be possible without additional relief. The petitioner requests modification, waver or exemption and clarification concerning the terms "congested areas" and "densely populated". The petitioner requests waiver forthis condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required. 

### 91.121 As discussed in Exemption 

### 11136 (ADVANCED AVIATIONS SOLUTIONS LLC) prior relief has been granted for manned aircraftto operate at lessthan the prescribed minimums, including Exemption Nos. 

### 2689,5745 and 

### 10650. In addition, similar UAS-specfic relief has been granted in Exemption Nos. 

### 8811, 10808 and 

### 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percenttothe PIC. The UAS batteries provide approximately 

### 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. These documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specific level. Given the limitationson proposed operations and the location ofthose

2of6proposed operations, the FAAfound that a reduced minimum power reserve forflight in daytime VFR conditions was reasonable. 

### 91.405(a); 91.407(a)(1); 91409(a)A(2); 91A17(a)A(b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure thatthe UAS is in a condition for safe flight in accordance with the operation documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and record keeping, were sufficientto ensure that safety would not be adversely affected.



### TbeUAS



### ·Yuneec QSOO Typhoon (N820BH pending) is a consumer grade small rotocraft in the

quadcopter configuration with a advertised weightof 1.3kg designed primarilyto carry a 4K high definition camera. It has advertised maximum speed of less than 30 knots and a maximum climb rate of600 feet per minute (3 m/s). It is powered byfour electric motors with a distance between motors of lessthan 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It iscontrolled primarilythrough an FCC certified radio control (RC) unit. Real time video information istransmitted backto a ground control station allowing the operator and/or PIC camera imagery and control camera angle. It · has fail safe modes ofoperation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed bythe PIC. Battery life limits flighttime to approximately 15 minutes. The onboard flight controller will warn the PIC via external light and audio cues before reaching a low battery state. An automatictermination offlight and landing will be initiated when battery reaches a predetermined low state.



### DJi Phantom Two Vision (N819BH pending) is a consumer grade small rotocraft in the quadcopter configuration with a advertised weight of 1.1 kg designed primarily to carry a high definition camera. It has advertised maximum speed of lessthan 30 knots and a maximum climb rate of 1200feet per minute (6 m/s). It is powered byfour electric motors with a distance between motors of lessthan 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarilythrough an FCC certified radio control (RC) unit. Real timevideo information istransmitted backto a ground

3 of 6control station allowing the operator and/or PIC camera imagery and control camera angle. It hasfail safe modes ofoperation for either loss of RC orGPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed bythe PIC. Battery life limits flighttime to approximately 15 minutes. The onboard flight controller will warn the PIC via external light and audio cues before reaching a low battery state. An automatictermination offlight and landing will be initiated when battery reaches a predetermined low state.



### Risk Mitigation

The petitioner has reviewed FAA exemptions reference's 1-3 Conditions and Limitations section and believes thatthe procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure thatthe UAairworthiness will be verified before each flight, maintaining flight and maintenance logs to record time on failure-prone components.

The petitioner requests that in a manner similarto reference 3, he be allowed to operate within 5 miles of an airport provided that; "The UA may notoperate in Class B, C, or D airspace without written approval from the FAA. The UAmay notoperate within 5 nautical miles ofthe 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 isconducted in accordance with a NOT AM as required bythe operator's COA. The letter of agreement with the airport management must be available totheAdministrator upon request.
Operations within 5 miles of an airport are notanticipated to be routine butthe petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within Class B airspace are not requested due to the lack of a mode C transponder.



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### Public lntrest

Use ofthe UAS in lieu of manned aircraftwould enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use ofthe UAS in orderto facilitate commerce could lead to economic growth. Operations forthis petition will enable service for property owners ortheir designees seeking an enhanced perspective for characteristics, amenities, and benefits oftheirdesired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhanced personal photography. Crop surveying applications could lead to decreased use of pesticides and fertilizer and conservation ofwater as well as increased crop yields and decreased costs. Aerial surveying and inspections
can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photographicdataforthese purposes on a ''for hire" basis acting asan independentcontractor. A visual observerwill be utilized. Liability insurance will be obtained commensurate with the granting ofthis requestfor exemption. Flight data including UAflight time, Control Unitoperation time, incident, accident, and details concerning any deviationsfrom normal operations will 

### be availableto FAAfor use in collecting date regarding the uses of UAS as partofthis application. This data may be submitted to the FAAvia traditional means, e.g. COA Monthly Reports, orother means as required.



### Conclusion

The petitioner is requesting this exemption forthe purpose of "aerial photography, cinematography, videography, mapping, crop surveying, inspections and otherflight operations". The reason for such a general and broad based request isthatthe petitioner wishesto utilize a business strategy of horizontal integration and maximize economies of scope in orderto capitalize on opportunities asthey may arise in the future without long turnaround time associated with additional exemptions. This petitioner's business model is based on the idea of offering ad hocsmall UAS servicesto individuals orcompanies who wish to employthese services as a safe, effective, and legal option to enhance their business or hobby. The petitioner's own market research showsthat pent up demand forthese services currently exists in the real estate market and other markets arejust beginning to emerge.


### 5of 6A quick internet search will showthat manyare currently operating similar UAS in exactly thisfashion without, it is assumed, FAA authorization. The petitioner has refrained from engaging in commercial use ofthe UAS. The primary purpose ofseeking this exemption isto obtain the capabilityto offerthose services while remaining in compliance, The petitioner has 25 years ofexperience in the hobbyof radio controlled aircraft.
Respectfully submitted, W. Dan Peters

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