# Au gust	27,	2015

U. S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590 Re: Exemption Request Section 333 of the FAA Reform Act. Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), E ye Spy

Security S ys tems, Sean Michael Clay Owner/ Operator plans to operator Smal Unmanned Aircraft Sy stems ( UAS) to conduct aeri al data collection, photograph y, videography, search and rescue and sur vey various ind

ustries hereb y applies for an exemption from Federal Aviation Regulations (FARs) to allo w commercial operation of m y UASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as requi red by

Section 333. Sean Michael Clay 3471 Biegler LN S Salem, OR 97302

I am a Commercial licensed instrument rated pilot. Being a commercial pilot I underst and safet y is paramount. Not only am I looking to use UAS to deliver a product to customer s , I am also looking to be a champion of the UAS industry by building positive relations hips throughout the community . By giving back to the community in a positive way by assisting local counties and Law Enforcement in areas such as Search And Rescue , b eing app roachable by the public , answering quest ions and educating the public to merit of UAS and that the word “drone” does not need to be a negative thing. Previous exemptions granted to similar businesses The following is list of recent exemptions granted to b usiness with similar operations and equipment: Exemption # 11458 5/5/2015 Christopher Gardner Exemption # 11464 5/5/2015 Michaels Drone Photograph y Exemption # 11455 5/5/2015 High Flight Photo
Ty pe of UAVs I currently operate are #1

- DJ I F450 Quad Copter #2

- DJ I F550 Hex Copter #3

- Yuneec Q500 Quad copter #4

- Yuneec H920 Hex CopterHow will my request benefit the public as a whole?

I am looking to provide affordable, safe options for aerial data collecting . Iwould like to start in the areas of pipeline and power line inspection, agriculture, as well as various uses by Fire and Law entities. Utilizing a UAS removes the need for full size aircraft, fuels and noise. Risk is mitigated by removing the required onboard crew from low and slow operating aircraft. I am hoping to nurture relationships with local Fire, Law and Rescue entities to provide much needed services. I envisions UAS being utilized on all ty pes of incidents. L ocal fire departments and Search an d Rescue crews are routinel y called to Injured or lost hikers . Unfortunatel y, man y of these individuals are unfamiliar with the trail sy stems. Cell phone “pinging” will get the general vic inity of the call, but the use UAS as an “eye in the sky” will great ly reduce the trial and error approach of determining which trail the victim is located on and possible save lives. Law enforcement routinely contacts fire departments to provide a ladder truck for “aerial photographs” of accident or crime scenes. The down side to this operation is the fact that ladder truck is now out of service or out of position for emergency calls. The use of UAS for law enforcement photograph y allows the fire trucks to remain available for other emergency calls. The se are just a few examples of use of UAS in coordination with Fire and L aw. The more discussions that occur, the more benefits will be realized. Utility workers are regularl y exposed to h igh voltage, electrical flash, h eights, and environmental dang ers. UAV operations would po tentially eliminate, or mitigate all of those risks to utility linemen. To ensure the reliability of our electrical sy stem, power lines must be patrolled regularl y through har sh and unforgiving terrain. When there is need for a closer inspection there is n o choice but to have a lineman climb up for a closer look, exposing them to electrical flash , electrical contact and falling hazard. UAS will remove a person from those unnecessary

exposures. It will also allow faster and more cost efficient inspections ensuring s ys tem reliability . When the use of thermal imaging is added to the process, it could find a potential problem before it causes s ys tem damage or more importantly

injury to an employee or a member of the public. The use of UAS in these dangerous jo bs will lower risk, increase s ys tem reliability , and most importantly protect lives. Utilizing UAS as an aerial based photography platform provides opportunities for photographic shots not prov ided by other means. For the general public or small business, full size aircraft for projects is just not feasible. I will bring aerial photograph y/videography to more businesses and artists. How will my request not adversel y affect safet y or provide a level of safety equal to an existing rule? The Reform Act direct s the Secretary of Transportation to consider whether operation of UAV can occur in the national airspace s ys tem (NAS) before the completion of the rulemaking required under Section 332 of the Reform Act. Eye Spy Security S ys tems bel ieve it is possible to operate UAS in a way to not create a hazard to the National Airspace S ys tem (NAS), the public or pose a threat to national securit y. I have demonstrated my willingness to act safel y and responsibly by not engaging in commercial UAS operations until the 333 exemption is granted. Duringmy feasibility s tudy , Ihave determined that there are man y operators offering their services to real estate agencies and parties in need of aerial photos. It is m y feeling that these ty

pe of operations, while may offer a quick fix, contribute to the negative attitude of the UAV. I am hoping to increase the safet y b y being professional, trained, insured and FAA compliant. I will operate under the following conditions, which provi de for safety equivalent to, if not exceeding the level required for manned aircraft

. S a f e ty w i l l b e th e f

i r s t an d foremost consideration in any UAS operation T h e UAS planned to be operated are rotorcraft and fixed wing aircraft, each weighing far less than 55 pounds including payload T h e y w o u l d o p e r at e , un d e r n o r m a l c o n d i t i o n s , at a s p e e d o f n o m o r e th an 5 0 knots. A l l o p e r at i o n s w i l l b e c o n d u c t e d b e l o w 4 0 0 ' A G L

. A l t i tu d e w i l l b e m o n i t o r e d v i a on screen display

or telemetry O p e r at i o n s w i l l b e c o n d

ucted during the day

under visual meteorological conditions A i r c r a f t w i l l r e m a i n w i th i n V i s u a l L i n e o f S i ght o f th e P I C o r V O ( v i s u a l o b s e r v e r ) at all times P I C an d V O w i l l r e m a i n i n v o i c e c o nt a c t d uri n g th e e nt i r e f

l i ght P I C s h a l l c o mp l e t e a f

u l l p r e
- flight inspection before every flight I will utilize additional observers or signage when operations are conducted close to public activity O p e r at i o n s w i l l o n l y b e c o n d u c t e d w i th p e r

m i s s i o n f r o m th e a p p r o p ri at e land/propert y owner A l l r e qu i r e d p e r

m its will be obtained from state and local government prior to operation T h e a i r c r a f

t w i l l n o t b e o p e r at e d o v e r p o p u l at e d ar e a s , l ar g e g ath e ri n g s o r heavily traveled roads. F l i ght p l ann i n g w i l l i n c l u d e f l i ght c o mp l e t i o n w i th at l e a s t 2 5 % b att e ry p o w e r r emaining as measured by the UAS flight computer or appropriate timing A l l a i r c r a f

t ar e e qu i p p e d w i th an d w i l l ut i l i z e GP S n av i g at i o n , f a i l s a f e , r e tur n
- to home (RTH) and/or flight abort safet y features T h e a i r c r a f

t w i l l n o t b e o p e r at e d w i th i n 5 N M o f a public airport or heliport A b ri e f i n g w i l l b e c o n d

u c t e d i n r e g ar d to the planned UAS operations prior to operation at each new location. All personnel who will be performing duties within the boundaries of the area of operation will be present for this b riefing T h e UAS pilot will be trained in advance for the safe o peration of the UAS to be operated. This will include operation of the UAS both in normal and emergency modes of operation, and will include familiarization with the operation manual. Training will also include ty pes of maneuvers to be performed and the safe operation in relation to persons, property and applicable airspace. Routine maintenance and repairs are instrumental in safe operations. All maintenance/overhauls/repairs will be co mpleted according to manufacturer instructions. Following all maintenance procedures, a test flight will be conducted in a remote area to assure all sy stems are operational prior to any operations for customers. Repairs and flight times will be documented to aid in tracking the life cycle of critical components (ie; batteries, motors and speed controls)The regulations from which the exemption is requested as well as how I intends to

provide an equal to or greater level of safet y are as follows:

- 14 CFR 45.23, 45.27 and 45.29

- Display of Marks, L ocation and Size Due to the size of the UAS, the required markings will be difficult to meet the minimum size standards. Also, due to the fact there is no cockpit and no persons shall be transported on UASs, disp laying “experimental” at an y location on the aircraft is not necessary

. My contact information shall be display ed on all aircraft in an eas y to locate location.

- 14 CFR Part 21 Subpart H, 91.7(a) and 91.203(a) and (b)

- Civil Aircraft: Certifications Requi red Carrying of civil aircraft certifications “onboard” or “displayed at the cabin or cockpit entrance” is not feasible due to size and no cockpit in the UAS. All applicable documentation shall be available on location where the pilot has immediate
access to them.

- 14 CFR 61.113 and 14 CFR 61.133

- Private Pilot Privileges and Limitations: Pilot In Command Private pilots may

not act as pilot in command and may not carry passengers or propert y for compensation. My objective is to conduct flights for compensat ion, although an equivalent or higher level of safet y is achieved due to the fact there will be no pilots or persons on board. All equipment carried shall be my personall y owned equipment A s s o l e p i l o t I am a c o mm e r c i a l / i n s tr um e nt r at e d p i l o t an d h av e o ver least 10 ye ars of RC experience and are current AMA members with no major accidents/injuries. This experience includes fixed wing, rotary and multirotor aircraft. Ut i l i z at i o n o f c o mp ut er b a s e d s i mu l at o r t o m a i n t a i n p r o f i c i e n c y an d a l l o w practice in a ll conditions as well as emergency procedures for simulated failures (Phoenix Flight Sim, Real Flight Simulator) T r a i n i n g thr o u gh s o m e o f th e m an y o n l i n e /h an d s
- on offerings from respected UAS training facilities. W e are aware of the reference to the Unmanned Aircraft Operator Certificate with Small UAS Rating as well as the Initial Aeronautical Knowledge Test referenced in NPRM 14 CFR Part 107 and Vol. 80, No. 35 Federal Register dated February 23rd, 2015. I strongl y agrees with this proposed course of action and will await a final ruling.

- 14 CFR 91.9 (b)(2): Civil Aircraft Flight Manual, Marking and Placard Requirements Carrying of a flight manual onboard is not app licable due to the size of the UAS. An equal to or h igher level of safet y will be achieved b y through familiarization of manufacturer limitations and procedures. All manuals will be easily accessible for reference at the location of the flight.

- 14 CFR 91.103

- Preflight Action Prior to arriving at flight lo cation, current and predicted weather, distances from airports as well as local hazards (power lines, towers, high occupancy areas) will be obtained. As stated above, a preflight briefing shall occur to include discussion regarding weather, emergency proce dures, hazards and alternate landing locations.

- 14 CFR 91.109

- Flight Instruction: Simulated Instrument Flight and Certain Flight Tests Dual controls for the purpose of flight instru ction is not applicable in the UAS operation. Should a need for instructi on arise, several methods of training are available.During designated training flights, the utilization of a “buddy box” system with 2

transmitters will provide an equivalent to or higher level of safety. Additionally the use of computer based flight simu lators provide the ability to conduct training with no safet y concerns.

- 14 CFR 91.119

- Minimum Safe Altitudes: The UAS shall be operated below 400 AGL standard. As a PIC of the UAS, being aware of the altitude minimums (with an emphasis on helicopters as they

may be operated lower altitudes more often) i s integral to safely operating UAS

.

- 14 CFR 91.121

- Altimeter Settings All UASs that Ioperate will utilize GPS altitude and/or barometric altimeters with data transmitted to the operator via telemetry and on screen display s.

- 14 CFR 91.151 (A): Fuel Requirements For Flight In VFR Conditions An equivalent or higher level of safet y is achieved in the fact that UASs do not
carry fuel. As stated above, all flights shall be planned and conducted with a minimum
o f 25% remaining battery power.

- 14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventative Maintenance And Alterations These regulations apply to aircraft requiring an airworthiness certificate. Adhering to manufacturer recommended maintenance, full pre

- flight and post flight inspections as well as documenting all maintenance performed will provide an equal to or greater than level of safety . After any maintenance has been completed, a test flight shall be conducted in a safe, non

- populated area prior to any commercial flight. Summary As the demand grows for aerial based photography applications, so will the temptation of individuals to util ize non

- compliant operators. I can deliver a product, safel y b y abiding b y all the rules and regulations. It is the applicant's belief that the size, speed, operating environment, limitations and level of applicant's experience outlined provides an "equivalent level of safe ty or better” when operating a UAS for the public interest as outlined in Section 333 in the F AA Modernization and Reform Act of 2012. lt is my

request that the FAA issue s an exemption to permit me safe, legal, Commercial UAS operation as soon as possible.

References Due to the size of the files, attaching them to this document did not seem prudent. The operator manuals can be accessed at utilizing the following links:

DJI450 http://www.dji.com/product/flame

- wheel

- arf

DJI550 htt p://www.dji.com/product/flame

- wheel

- arf
Yuneec Q500 http://y uneec.com/products/aerialuav/q500_4k/

Yuneec H920 http://y uneec.com/produ cts/aerialuav/h920/