**Michael L. A llen**  **6042 Instone Circle Colorado Springs, CO 80922**  **Tel: (719) 310 -** **4789 Mallen12064@gmail.com**  February 2 , 2016 To the FAA, This petition is being submitted on my own behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Michael L. Allen, a private individual, operating a Small Unmanned Aircraft System (" sUAS") equipped to conduct aerial photography and survey for various industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of my sUAS commercially in airspace regulated by the Federal Aviat ion Administration (FAA), so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption would permit Michael L. Allen to pursue commercial in terests in providing services to consumers interested in aerial data capture using a small advanced sUAS in the following areas:

 Media Production  Real Estate Inspection & Sales  Agricultural, Livestock & Land Surveying  Aerial Mapping  Search and Rescue O perations  sUAS Operator Training  Product Demonstrations  Research and Development Michael L. Allen states that all sUAS flights that will occur over private or controlled access property will do so with the property owner's prior consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where photography and videography will take place will be captured in identifiable form. Additionally, Michael L. Allen PIC (Pilot
- In
- Command) holds a Commercial Pilot ASEL/AML/ Instrument certificate. If observers are not qualified pilots, they will be trained by Michael L. Allen to understand the proper roles of an observer, communication procedures, proper visual scan techniques, operations at non
-towered airports, and appropriate sections of the Aeronautical Information Manual.**Regulations from which the exemption is requeste d:** 

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91. 215 14 C.F .R. (91.401
- 91.417) **Small Unmanned A ircraft Sy** **stem (sUA S)**  sUAS are a highly effective tool for obtaining agricultural cropland data which aides in determining optimal irrigation and fertilization requirements . This result s in cost savings a nd avoid s environmental impact from excess fertilization. Livestock safety and security also benefit from the sUAS as the conservative power requirements enable more frequent monitoring which would be cost prohibitive from a traditional manned aircraft. As an aerial camera platform, sUAS also perform valuable commercial media, film , photography and 3D mapping functions more safely and effectively than other means. Additional benefit from the sUAS also is apparent through assisting local authorities in coordinated Search
-And
- Rescue operations. I am petitioning for exemption to operate a DJI Phantom 3 multi
- rotor equipped with a three
- axis gimbaled camera, and a DJI Inspire 1 multi
- rotor equipped with a three
- axis gimbaled camera. These sUAS all weigh less than 55 lbs., all have a built
- in capability to limit the height flown above the ground and to limit the radius of the distance flown from the operator and to exclude the sUAS from Class B, C and D airspace including a no fly zone feature. Each system also has a failsafe function of an autopilot system, which triggers GPS Return to Home and Land capability in the event of disrupted communication with the Main Controller. Each sUAS uses four counter
- rotating propellers that provide balance, stability and control in all segments of flight. Fully equipped with battery , gimbal and camera , each sUAS weighs less than 55 pounds. Primary operation of the sUAS involves a visual survey of the intended subject area, updating the deployment destinati on point in the event of a return
- to
- home trigger, vertical deployment to less than 400’ AGL, enroute travel at less than 50 knot maximum speed. All operations are conducted under visual meteorological conditions (VMC) within visual line
- of
sight (VLOS) of the remote control and PIC

.The above specifications meet standards listed below, some derived in accordance with the

Model Aircraft Operating Standards: • The petitioner will only operate its sUAS in line
- of
- sight of a pilot and/or observer and will operate at a 'sufficient distance' from populated areas. Such operations will insure that the sUAS will "not create a hazard to users of the national airspace system or the public." • W hen flying sUAS within 5 miles of an airport, airport operators will be notified and the operator will give the right of way to avoid flying in the proximity of full
- scale aircraft. • Maximum flight time for each operational flight will be 60 minutes. • Flights will be terminated at 25% battery power reserve should tha t occur prior to the 60 minute limit

. • The sUAS will be programmed so that it will not be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. • The sUAS PIC (Pilot in Command) will hold a FAA Commercial Pilot Certificate. • The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). • The sUAS will operate at speeds of no more than 55 knots. • Given the small size of the sUAS and the restricted sterile environment within which they will operate, the sUAS operations adhere to the Reform Act's safety requirements.**Summary**



### Michael L. Allen’s operation of s ma ll unm anned aircraft w ill not "create a hazard to users of the national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the sm all size and weight of the sUAS, com bined w ith safety focused operation standards, Michael L. Allen ’s flight operations fall within Congress's contem plated safety zone w hen it dissem inated the Reform Act and the corresponding directive to integrate UASs into the national airspace system. Michael L. Allen has extensive knowledge of and experience with sUAS system s, and has a high regard to safety and coordination with commercial and general aviation. Additionally, the fact that Michael L. Allen holds a Commercial Pilot certificate dem onstrates he has a high regard to safe operations with an understandin g of FARs, preflight inspections, maintenance and repair, operations within airspace, as well as being trained to high safety standards. Michael L. Allen ensures he is fam iliar with all applicable regulations and guidance docum ents pertaining to sUAS operation ; including background inform ation such as sectional aeronautical charts for each area of operation , NOTAMS and Aircraft Circulars; Radio Comm unications Procedures; Hum an Factors and Crew Resource Managem ent; Basic Sm all UAS Aerodynam ics; We ather fact ors; Airmanship and Decision
- ma king and Safe Operating Procedures. Michael L. Allen respectfully requests exem ption under Section 333 to operate safe, low
- risk commercial sUAS operations for the activities stated. Michael L. Allen, at all tim es, w ill res pect the space and privacy of citizens and property while keeping our skies safe. Sincerely, Michael L. Allen 6042 Instone Circle Colorado Springs, CO 80922