### UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Sean P. Payne

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS Part 21, Subpart H ; 45.23(b); 61 .113(a); 61.113(b ); 91.7(a); 91.9(b)(2); 91.103 ; 91.109; 91.119(c); 91.121; 91.151( a); 91.203(a)&(b); 91

. 405(a); 91

. 407(a)(1); 91.409 (a)( 1 );

91

. 409(a)(2); 91.417(a) & (b); CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3, DJI Phantom 2 and DJI Inspire 1 UNMANNED AIRCRAFT

SYSTEMS FOR PURPOSES OF AERIAL DATA COLLECTION

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on September 3, 2015

Sean P. Payne
2426 Ontario Road NW, APT. #306

Washington, D.C. 20009Table of Contents

Summary

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Name and Address of Applicant

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Petitioner’s Statement

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Exemptions Requested

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The sUAS Proposed for Operation U nder the Petitioner’s Exemption

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Risk Mitigation

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Statement of Public Interest

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Attachment: Copy of Private Pilot Certificate

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Attachment: Copy of Current Third Class Medical Cert ificate

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Attachment: DJI Phantom 2 User Manual V. 1.4

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- 1

Attachment: DJI Phantom 3 User Manual V. 1.4

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- 1

Attachment: DJI Phantom Inspire 1 User Manual V. 1.4

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- 1

Attachment: Freefly Systems Alta User Manual Rev. B

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- 1

Attachment: Motion Picture and Television Flight Operat ion Manual

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . E

- 1Glossary of Abbreviations

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Not ice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System

UA Unmanned Aircraft

VFR Visual Fl ight Rules

VLOS Visual Line of Site

VMC Visual Met eorological Conditions

VTOL Vertical Takeoff and Landing1 Sean P. Payne
2426 Ontario Road NW, APT. #306

Washington, D.C. 20009

August 15, 2015

U.S. Department of Transportation
Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Attachments: 1) Copy of Petitioner’s Private Pilot Certificate.

2) Copy of Petitioner’s Current Third Class Medical Certificate 3) DJI Phantom 2 v.2.0 User Manual V. 1.4 4) DJI Phantom 3 User Manual V. 1 .4 5) DJI Inspire 1 User Manual V. 1.4 6) Freefly Systems Alta User Manual Rev. B. 7) Motion Picture and Television Flight Operation Manual

References : 1) FAA Exemption No. 11138, Re gulatory Docket No. FAA20140481 In the matter of

the petition of DOUGLAS TRUDEAU

. 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

- 2014

- 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Re gulatory Docket No. FAA20140355 In the matter of the petition of FLYING CAM INC

To Whom It May Concern :

In accordance with the FAA's Guidelines/or Submitting a Petition/or Exemption under section 333 of the FAA Modernization and Reform Act 0/2012

, Sean P. Payne

, referred to hereafter as the petitioner

, request exemption from the following sections of Title 14

, Code of Federal Regulations §§

Part 21, Subpart H ; 45.23(b); 61 .113(a); 61.113(b ); 91.7(a); 91.9(b)(2); 91.103 ; 91.109; 91.119(c); 91.121; 91.151( a); 91.203(a)&(b); 91

. 405(a); 91

. 407(a)(1); 91.409 (a)( 1 ); 91

. 409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the pur poses of aerial data collection including: environmental mapping, crop surveying, aerial photography, cinematograph y , videography that can be performed safely and more cost effectively with the use of small sUAS at low altitude within the U. S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request of
and with the aut horization and permission of clients or their authorized agents in order to facilitate

comm erce and raise awareness of the beneficial uses of small unmanned air systems. So long as such2

op erations are conducted within and under the conditions outlined here in or as may be establ ished by the FAA as required by Section 333. The conditions identified and proposed by the petit ioner are drawn
from references 1

- 3.

Name and Address of Applicant /Petitioner Sean P. Payne
2426 Ontario Road NW, APT. #306
Washington, D.C. 20009

973

- 583

- 2793 airplanedetective@gmail.com

Petitioner’s Statement I am an experienced sUAS operator, certificated private pilot holding a current third class medical certificate and work professionally as a mechanical/aerospace engineer. I have been involved in remote
aircraft and sUAS activities since 1993 and have expe rience with a wide range fixed wing, rotary wing and multirotor sUAS systems as well as full size passenger carrying aircraft and rotorcraft.

Though I live within the Flight Restricted Zone (FRZ)

, all of my sUAS flight operations and experience has

been c onducted outside of the FRZ and within the current proposed rulemaking established by the FAA put forth at the time of petitioning.

I am seeking an exemption for the use of sUAS vehicles for aerial data collection outside a closed set

environment and for the utilization of sUAS vehicles for the purpose of aerial data collection within a
closed set environment.

TheFARs The petitioner seeks exemption from the FARs mentioned on page one of this submission for the following reasons;

14 C.F.R

. 21, Subpart H, entitled Airworthiness Certificat es, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91

. 203(a)(l). The size, weight and enclosed operational area of the petitioner’s UAS permits ex emption from Part 2 because my UAS meets (and exceeds) an equivalent level of safety pursua nt to Section 333 of the Reform Act

. The F AA is authorized to exempt aircraft from the airworthiness certificate re quirement under both the Act (49 U.S.C. § 44701 (f) and Section 333 o f the Reform Act

. Both pieces of legislation permit t he FAA to exempt UAS's from
the airworthi ness certificate requirement in consideration of the weight, size, speed, maneuverability and prox imity to areas such as airports and dense populations. The petit ioner’s current and projected

UASs meet or exceed each of the elements.

45.23(b) The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also3

display on that aircraft ne ar each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no a irworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAV, two

- inch lettering will be impossible. The word “Experi mental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

61.113(a) & (b); The petitioner requests relief in order to faci l i tate the utilizat ion of pilots, who hold a SPORT PILOT (or greater) certificate. We can achiev e an equivalent level of safety as achieved by current Regulations because the petitioner’s sUAS do not carr y any pilots or passengers. The risks attended to the operation of the petitioner’s sUAS is far less than the ri sk levels inherent in the commercial activities
outlined in 14 C.F.R

. § 61, et seq. Thus, allowing the petitioner to operate the sUAS in a manner that meet and exceed current safety levels in relation to 14 C

. P.R

. § 61

. 113 (a) & (b). In addition, Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a
hazard to persons or property on the ground.

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 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

airc raft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides:

No person may operate a U.S.

- registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

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 eq uivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following4

exemptions to this regulation: Exemption Nos. 8607, 8737 , 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

91.103; Preflight Action This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manua ls will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in the operations manual for each sUAS (attached to this exemption consideration) . The PIC will take all actions including rev iewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

91.109; Flight instruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning
dual controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual

contro ls for a number of aircraft and for flight instruction in experimental aircraft. 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 and by the size and sp eed of the aircraft.

91.119( c) Establishes safe altitudes for operation of civil aircraft. Specifically, 91

. 119( c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsel y populated areas. In those cases, the ai rcraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. As set forth herein, the sUAS will not operate at higher than 400 feet AGL

. The sUAS will, however, be operated to avoid congested or populated areas.

Because aer ial data collection must be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91

. 119( c) is needed. The equivalent level of safety w ill be achieved given the size, weight, speed, and material with which the sUAS are built

. Also, no flight will
takeoff or land without the permission of the land owner or those who control the l and. Because of the
advance notice to the landowner, all affected individual s will be aware of the flights. Compared to operations conducted with aircraft or rotorcraft w eighing far more than the sUAS, and carrying flammable fuel, any risk associated with these operat ions will be significantly less than those currently
allowed wit h conventional aircraft operating at or below 500 feet AGL. Indeed, the low

- altit ude operations of the sUAS will maintain separation from operations of conventional aircraft that must comply with Section 91

. 119.

91.121 As discussed in Exemption 11138 (DOU GLAS TRU DEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic G PS with a barometric sensor for altitude information. To provide an equivalent level of safety, th e sUAS autopilot will calculate the ground level with the on

board GPS during the pre

- flight tests. The GPS and barometer data are merged with their respective precisions. The GPS provides reliable information to correct potential barometric bias, while rapid variations in altitude are detected through the ba rometer

.

91.151(a) A s discussed in Exemption 11136 ( ADVANCE D AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at les s than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for d aytime, VFR conditions. The UAS provides battery power remaining in percent to5

the PIC. The UA batteries provide approximately 10

- 25 minutes of powered flight for t he sUAS discussed in this petition . An equivalent level of safety can be achieved by maintaining the manufacturer recommended minimum minutes of reserve fuel, which would be more than adequate to return the

s UAS to its planned landing zone from anywhere in its operating area gi ven that the systems are designed to be flown within direct VLOS of the PIC. Inform ation provided in the operating documents discusses procedures regarding remaining battery power management

. Those documents contain a
condition in whi ch the PIC will initiate a landing procedure when battery remaining reaches a specified
level

. Given the limitations on proposed operations and the location of those proposed operations, The
FAA found that a reduced minimum power reserve for flight in dayt ime VFR conditions was reasonable.

91.203(a)&(b); Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent
part: (a) Except as provided in § 91.715, no person may operate a civil

aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is display ed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration docume nts or to display them on the

sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to
the sUAS. Th e 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.

91

. 405(a); 91

. 407(a)(I); 91

. 409 (a)(I) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner prop oses to inspect and ensure that the UAS is in a condition for safe flight in
accordance with t he operating documents. The FAA found that adherence to the petitioner's operating
document s and the conditions and limitations specified, describing the requirements for maintenance, inspection , and recordkeeping, were sufficient to ensure that safety would not be adversely affected . An equivalent level of safety will be achieved because the sUAS are small in size, wi ll solely operate in
restricted predetermined areas and are not complex mechanical devices. We will perform all

maintenance and inspections in accordance with the manufacturers' manual s and any required
manufacturer Safety or Serv ice Bulletins. In addition, the PIC will conduct a p reflight inspection of the

sUAS and all associated equipment to account for all discrepancies.

The sUAS Proposed for Operation Under the Petitioner’s Exemption

DJI Phantom 2 v.2.0
The DJI Phantom 2 v.2. 0 is a consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 44 ounces designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots and a maximum clim b rate of less than 1200 feet6

per minute. It is powered by four electric motors with a distance between motors of less than 14 inches. 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 primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level

, GPS signal strength

, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight con troller and maximum altitude can be preprogrammed by the PIC. Battery life limits f light times to approximately 20 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An a utomatic termination of flight and landing will be initiated when the battery reaches a predetermined low state

. It is anticipated that flights will usually
last less than 10 minutes. More information is available i n attachment 3

.

DJI Phantom 3
The DJI Phantom 3 is a consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 44 ounces designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots and a maximum climb rate of less than 1200 feet per minute. It is powered by four electric motors with a distance between motors of less than 14 inches. It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with glo bal positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowin g the operator and/or PIC to monitor battery level

, GPS signal strength

, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onb oard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits f light times to approximately 20 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low batt ery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state

. It is anticipated that flights will usually
last less than 10 minutes. More information is available i n attachment 4

.

DJI Inspi re 1
The DJI Inspire 1 is a consumer grade small rotorcraft in the quadcopter configuration with an advertised maximum gross weight of 6 pounds 7.5 ounces designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of les s than 42 knots and a maximum climb rate of less than 1200 feet per minute. It is powered by four electric motors with a distance between motors of approximately 17 inches . 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 primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a groun d control station allowing the operator and/or PIC to monitor battery level

, GPS signal strength

, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits f light times to approximately 20 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues b efore reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state

. It is anticipated that flights will usually last less than 10 minutes. More information is available i n attachment 5.7

Freefly Systems Alta
Alta is a hexa

- rotor drone for aerial imaging that

- when used in conjunction with a separately available MoVI gimbal

- supports mounting the camera either below or above the airframe. This configuration
allows camera and sensor packages to be mounted in a variety of positions, for a variety of applications. Alta features a maximum payload of 15 lb , which is suitable for DSLRs, mirrorless cameras, and even compact cinema cameras (depending on lens weight and other varia bles). Equipped with a proprietary flight control system, Alta works with a range of transmitters operating on the 2.4 gHz band . Flight modes provided include Manual, Height Hold, Climb Rate Control (Vario), Position Hold, Ground Speed Control, Return

- To

- H ome , and Auto

- land. For monitoring, the flight controller can be used in conjunction with a variety of video transmission equipment to assist in framing cinema

- graphic shots or sensor readings

. The system has an onscreen display ( OSD ) and is user

- configura ble

. Telemetry data can also be displayed on compatible 2.4 gHz band transmitters. The system has a maximum gross takeoff weight of 29.9 lbs and a top speed of about 45 miles per hour (mph) (39 knots).

Risk Mitigation The pet i tioner has reviewe d FAA exemptions references 1

- 3 Conditions and Limitations section and
believe s that the p rocedures specified therein are reasonab l e and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist is employed to en sure that the UA

airwor thiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone
components.

The petitioner re quest that in a manner similar to reference 3, he be allowed to operate within 5 miles of an airport provided that;

"The VA may not operate in Class B, C, or D airspace without written approval from the FAA

. The UA may not operate 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 a NOTAM as required by the operator's COA. The letter of agreement with the airport management must be made available to the Administrator
upon request. "

Operations within 5 miles of an airport are not anticipated to b e routine but the petitioner is requesting
a mechanism to facil itate such activities withou t requesting a new and separate exemption(s) should the need arise. Operations within class B ai rspace are not requested due to the lack of mode C transponder.

In addition to the minimum pilot certifications required by the FAA

, as pilot the petitioner will:

1) Have flown and logged a minimum of 150 flight cycles and 25 hours of total time as a sUAS pilot for a given category of sUAS (rotorcraft or fixed

- wing) and at least 10 hours logged as a sUAS pilot with a similar VAS type (single blade or multi

- rotor).

2) Have flown and logged a minimum o f five hours as UA S pilot with the make and model of the
sUAS as well as three take

- offs and landings in the preceding 90 days.

Public Interest
Use of the sUAS in lieu of a manned aircraft w ould enhance safe ty and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions

, carrying a9

Attachment 1: Sean P. Payne Private Pilot Certificate10

Attachment 2: Copy of Current Third Class Medical Certificate