**Sept 1**  **9**

**, 2015** 

**U. S. Department of Transportation Docket Management System 1200 New Jersey Ave,**  **SE Washington, DC 2059**

**Richard O. Oexmann is a FAA licen sed ATP, MultiEngine, Commercial SEL, Rotorcraft** 

**** **Helicopter Pilot Certificate**  **# 1645002 Florida Real**  **Es tate Licensed Agent # SL3320779** 

Re: **Section 333** Exemption Request Pursuant To Section 333 of th e FAA Reform Act of 2012

Dear Sir or Madam: Pursuant to §333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11,

Richard O. Oexmann

, operator of Small Unmanned Aircraft Sy stems (sUAS) equipped to conduct aerial photography for Real Estate advertising and other photography and videography

for civil business purposes in controlled areas , hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial

o peration of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federa l Aviation Administration (FAA) as required by § 333. As described more fu ll y below

, the requested exemption woul d permit the operation of small, unmanned and re l ativel y inexpensive multirotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on s ite safety personnel controlling access, and 4) would provide increased safety

and enhancements to clients' business operations. The specific sUAS is the DJI Phantom 2 Vision Quad Copter Rotorcraft weighing less than 55 pounds including onboard factory mounted DJI camera. It operates at a speed less than 50 knots and has the capability

to move in the vertical and horizontal plane simultaneously . The DJI Phantom 2 Vision has an auto return to launch point when battery p ower is under 25% and/or the signal is lost between the rotorcraft and the controller. The name and address of the applicant is:

**Richard O. Oexmann ATP Multi E**  **ngine, Commercial SEL, Rotorcraft** 

**- Helicopter**  **P ilot**  **, certificate # 1645002**  **Florida Realtor license #**  **SL3320779 Address: 18 Cedarford Ct., Palm Coast, Florida 32137**  **Richard O. Oexmann phone: 210**

**- 413** 

**- 7717**  **Email: roexmann7@hotmail.com** I, Richard O. Oexmann respectfully requests a grant of an exemption of the following sections of Title 14 of the code of Federal Regulations: 14 CFR 21; 14 CFR 91, et seq.; 14 CFR 45.23(b); Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

. 14 CFR 6 1.113 (a) & (b); 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); 14 CFR 417 (a) & (b).

I, Richard O. Oexmann also respectfully requests an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

14 CFR 45.23(b) ; 14 CFR Part 21 ; 14 CFR 61.11 3 (a) & (b) ; 91.7 (a); 91.9(b)(2); 91.103(b) ; • 91.109 ; 91.119; • 91.12 1 ; 91.151(a) ; 91.203 (a) & (b) ; 91.405 (a);

• 91.407 (a) (1); 91.409 (a) (2) ; 91.417 (a) & (b).

The Extent of Re l ie f Richard O. Oexmann Seeks and th e Re ason I t Seeks Suc h Re lie f : Richard O. Oexmann submits this application in accordance with the Refo rm Act, 112 P.L. 95 §§ 331334, seeking relief from any currently applicable federal aviation regulations FARs pertaining to UASs (unmanned aircraft sy stems) and operating to prevent Richard O. Oexmann contemplated commercial photography , videography and other fl ight operations within the U.S. nationa l airspace sy stem. The Reform Act in §332 provides for such integration of civil UASs into our national airspace sy stem as it is in the public's interest to do so. Richard O. Oexmann lightweight UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safety record in similar industri es, Richard O. Oexmann light duty UASs are ideal recipients of exemption by the intent of the Reform Act Considerations for relief include a combination of sUAS ’s phy sical characte ri stics, safety features, and safe practices identified in § 333: • sUAS weight, • sUAS overall size, • sUAS speed over ground, • sUAS flight zone characteristics, Non operation near airports (civilian or military) ,Tightly contro lled operation in populated areas. Specific conside rati on is outlined below

. Operation of the UAS by VLOS by 1 4 C.F.R. Pa r t 2 1
, Sub p art H : Airworthin ess Certi fi cat es 14 C.F. R . § 91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes the procedural re quirement s for th e issuance of airworthiness certificate s as required by F AR §91.203 (a) (1 )

. Given the size and limited ope ratin g area associated sUAS ’ s, an exemption from Part 21 Subpart H m eet s the requirements of an e quivale nt l evel of safety under Part 11 and §333 of th e R efo rm Act. 1l1e Federal Aviation Act (49 U.S.C .§4470 1 (f) and §333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness ce rtificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the particul ar sUAS. In all cases, an anal ys is of these criteria demonstrat es that th e UAS operated without an airworthiness certific ate , in the r es tricted environment andunder the conditions proposed will be at least as safe, or safer, than a conve ntional

airc raft (fixed wing or rotorcraft) operating with an airworthiness certificat e without the restrictions and conditions proposed. The sUAS to be operated by Richard O. Oexmann is les s than 1 1 kg. with maximal
payload consisting of remote se n sing instrumentation, carr i es neither no per sons, carries

no explosive or flammable mate rial s including combustibl e fuels, and operates exclusively within a secured area. Unlike other civil airc raft

, operations under this exemption will be tightly controlled and monitored by the pilot (P I C), whose role is designated to act as both the remote sensing controller and secondary mo nitor for safety i ssues, and a technician, which assists in matters related to maintaining the sUAS and also monitors for sa fety c oncern s and liaisons to the on s it e safety officials. These enhancements to current safety p ractices and regulations, which already apply to civ il aircraft, provide a greater degree of safety to the public and property owners than conventional aircraf

t operation s conducte d with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H

. Lastly

, application of these same crite ria demonstrates that there is no intrin sic cre dibl e threat to national security po se d by the UAS, due to its size, s peed of operation, lo cation of operation, l ack of intrinsic exp l osive materials or flammable liquid fuels, and inability to carry a substantial exte rn a l load. 1 4 C.F.R. §45.23 (b ). Marking of th e Airc raft The regulation requires: When marks include only th e Roman capit a l l e tte r "N" and the registration number is displaye d on limite d

, re stricted or light sport category aircraft or experime ntal or provisionall y certificate d aircraft, the operator must al so display on that aircraft n ear eac h e ntran ce to th e cabin , cockpit, or pilot station, in l etter s n ot l ess than 2 inch es nor more than 6 inch es high, the words " limit ed ; "restricted ; "light sport ” "expe rim e nta l ; or "provisional ” ; as applicable. Even though the sUAS will have no airworthiness certificate, an exe mpti on

may be n ee ded as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Exper im enta l " can be placed. Gi ven the size of the sUAS, two inch lettering will be impossible. The wo rd "Expe rim ental" will be placed on the frame in compliance with §45.29 (f) at a size suitable for the available space. The equivalent level of safety will be provided by

having the sUAS marked on its fuselage as required by §45.29 ( f) where the pilot, observer and other s working with the sUAV will see the identification of the UAS as "Expe ri mental." The FAA has issued the following

exe mpti ons to this regulation to Exem ptions Nos. 10700, 8738, 101 67 and 101 67A. Further markings includ e the use of flashing green LED illumination on the underside of the sUAS frame which s tand s at co ntra st against a blue or white sky

.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 14 C.F. R. §6 1.11 3 (a) & (b): Private Pilot Privil eges and Limitations: Pilot in Command. §61.113 (a) & (b) limit private pilots to non commercial operations. Because the sUAS will not carry a pilot or passengers, th e proposed
ope rations can achieve the equivalent lev el of safety of current operations by

requiring a ground crew me mber to have a private pilot's license rather than a comme rcial pilot'slic ense to operate this sUAS. Unlike a conventional aircraft that carries the pilot and

passengers, the sUAS is remotely controlled with no persons on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance

. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds the present l evel of safety achieved by

14 C.F .R. §61.1 1 3 (a) & (b). 1 4 C.F .R. §91.7(a): C ivil aircraft airworthiness. The regulation requires that no person

may operate a civil aircraft unl ess it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 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, a subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be provided. 14 C.F.R. §91.9 (b) (2): C i v il Aircraft Flight Manual in th e Aircraft. §91.9 (b) (2) provides: No perso n may operate a U.S. registered civil aircraft ... (2) f or which an Airplane or Rotorcraft F light Manual is not required by

§21.5 of this chapter, unles s th e re is available in the aircraft a

c urrent approved airpl ane or Rotorcraft F li ght Manual, approved manual material, markings, and pl acards, or any combination thereof. The sUAS, given its size and configuration has no ability to carry a phy sical flight manual on the aircraft. The equivalent 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 iss ued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 92 99A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. 14 C.F.R. §9 1.10 3: Preflight action

. This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals wil l not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Further, we have manuals

created with the help of sUAS experts, the manufacturer of the sUAS, to ensure best safe practices are adhered to. 14 C.P.R. §91.1 09: Flight in s truction §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 accompl ished 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 controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety is provided by the fact that neither a pilo t nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Enhancing this safety is the t echnology inh ere nt in the remote controls utilizing digital communi cati on s wh i ch is paired to the sUAS making i t n early impossible to unintentionally or intentionally h ave the control communi cations interrupted.1 4 C.F.R. §9 1.119 : M ini mum safe altitudes §91.119 establishes safe altitudes for

operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimum s prescribed, provided the person operating the h e li co pt er complies with any route or alti tudes prescribed for helicopters by the FAA. As this exe mptio n is for a sUAS that closely

mimic s the behavior of a h elicopter, and the exemption reque sts authority t o operate at altitudes up to 400 AG L, an exempt ion may be needed to allow such operations. As se t forth herein, th e UAS will never operate at higher than 400 AGL or b eyo nd unaided visual line of sight, whichever i s closer. It will however be operated in a

res tricte d area with sec urity officials tasked with ensuring pub li c safe ty , and where buildings and people will not be exposed to operations without their pre o btained consent and training. The equival e nt l e vel of safety w ill be achieved given th e size, weight, speed of th e UAS as well as the location wh e re it i s o p erated . No flight operation will be take n without th e permission of th e property owner in the case of private pr ope rty o r loc a l officials In the case of public prope rty or private property with public interests. B ecau se of th e advanc e notice to the property owner and participants in the remote sensing activity , all affected indiv idual s will be aware of the planned flight operations. Compared
t o flight operations with aircraft o r rotorcraft weighting far more than the maximum 1 1kg of Richard O. Oexmann sUASs proposed herein and the lack of flammable fuel, any risk associate d with these operations i s far l ess than those presently pre se nt ed with conventiona l aircraft operating at or below 500 AGL. In addition, the low altit ud e operations of the sUAS will e n sure separation between these s mall UAS operations and the operatio ns of conventiona l aircraft that must comply with §91.119. 14 C.F. R

. § 91. 1 21 Altimeter s ettings §91.121 requires eac h person operating an aircraft to maint ain cruis in g

a ltitud e by refe rence to an alti meter that is set " ...to the elevati on of the departure airport

or an appropri ate a ltim ete r setting available before d eparture." A s th e sUAS may not have a barometric altimeter, but instead a GPS altitude read out. An equiva lent leve l of safety wi ll b e achieved by th e operator, confirming the altitud e of th e launch s ite sh own on the GPS altitude indicator b efore flight. The operator will also ensure effective pairing with multiple GPS sources to guarantee accurate dete c tion of height. 14 C.F.R. §9 1.15l (a): Fue l Requirements for Flight in VFR Conditions §9 1.1 5 1 (a) prohibits an individual from beginning "a flight in an airplan e und er VFR conditions unl ess (considering wind

an d fo recast weather conditions) there i s enough fuel to fly to the first point of intend ed landing, and, assuming normal cruising speed ( 1) During the d ay , to fly after that for at least 30 minut es ; or (2) At night, to fly after that for at l east 45 minutes: The batt ery powering the sUAS provides approximately 2 5 minutes of powered flight in hover mode without payl oad. Richard O. Oexmann sUAS will not be able to meet the 30 minute

reserve requirement in 14 CF R §9 1.15 1. Operating the small UAS, in a tightly controlled

area where on l y people and property owners or official representatives who have signed

wa i vers will be allowe d , with less than 30 minutes of reserve powe r , does not enge nde r the ty pe of risks that Sectio n 9l.l51(a) was intended t o alleviate give n the size and speed of the s mall UAS. Richard O. Oexmann believes that an equivalent level of safety

can be achieved by limiting flights to 15 minutes or 50% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to it’splanned landing zone from any where in its limit ed o perating area

. Similar exe mption s h ave been granted to other operation s, includin g E x em ptions 2689F, 5745, 10673
, and 1080. 1 4 C.F. R . §9 1. 20 3 (a) & (b): Carryin g Civ il A ircraft Certificati on 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 civi l aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91. 715 is displaye d at the cabin or cockpit entrance so that it is legible to passengers or

crew. The sUAS fully

loaded weighs no more than ll kg and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS

. An equivalent level of safety wi ll 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. The 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. 1 4 C.F. R. § 9 1. 405 (a) ; 4 0 7 (a) ( 1 ) ; 4 0 9 (a) (2) ; 4 1 7(a) & (b ): Maintenan ce Inspect i o n s These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

. .. ; and others shall inspect

o r maintain the aircraft in compliance with Part 43

. Given that these section and Part 43 apply only to aircraft with an airworthin ess certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator and recorded in a log book

. An equivalent level of safety will be achieved because these sma ll UASs are very limited in size and will carry

a small payl oad and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to ini tiating flight, perform required maintenance, and keep a log of
any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equival ent level of safety

. An exemption granted to Richard O. Oexmann woul d permit its operation of lightweight, unmanned, remotely

controlled, sUASs in a tightly controlled environment with limited airspace. Richard O. Oexmann utilizes local business' safety o fficers in specifically determined areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goal s. Technical enhancements to current safety controls will allow Richard O. Oexmann to operate exceeding current safety specifications, and stay

ahead of, or meet, new ones being impl emented by the FAA and Department of Transportation. Further, Richard O. Oexmann conducts its operations in com pliance with protocols described here in or as otherwise established by th e FAA.

### II. C o m me rci a l and Publi c Benefit s;

I Richard O. Oexmann believe that granting this exemption request furthers the public interest by providing safe (by way of an unmanned system) and efficient

means to Richard O. Oexmann ’ s customer base are typically small to medium sized business' looking to increase their awareness of respective properties. Aerial videography and photography for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners and homeowners its expense has been cost prohibitive. Granting this exemption to th e petitioner would allow him to provide this service at a much lower cost. Further, the petitioner indicates his small UAS will pose no threat to the public given its small si ze and lack of combustible fuel when compared to larger manned aircraft. The petitioner also states that the operation of his UAS will minimize ecological damage and promote economic growth by providing information to small busines ses and individua ls looking to relocate or build in the Palm Coast, St. Augustine, Daytona Beach , and Northeast Florida area.

By photographic or videography . By moving these functions onto sUAS base d a ircraft,
the potential for l oss of life or property i s diminished due to the greater contro l in a smaller and safe r aircraft that holds no persons. Second, th ere are n o r eac tiv e or combustible material s on board the sUAS and thus the potentia l for fire or explosions i s greatly diminished. Third

, the s mall si ze and extreme maneuverability Richard O. Oexmann ’

s UASs allow the PIC to avoi d hazards. Accordingly

, Richard O. Oexmann ’ s UASs have operated and will continue to operate at and above current safety levels.

A

. The c osts and b enefits of your propos ed a ction t o society in general and speci fi c gro up s wi thin s ociety . A s d escribed above, Richard O. Oexmann ’ s past customers hav e been small to medium business seeking Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and hel icopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. Only

large companies and high end Realtors or luxury

homeowners can afford to absorb such expense. Depriving non luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic rash that the various communities have experi enced in the past with military aircraft and medical helicopter crashes within even cities. Each resulting in loss of life, each with combustible fuel that exploded and burned on impact. My
, Richard O. Oexmann 's, sUAS pose no such threat since size and la ck of combustible fuel alleviates any potential threat to the public. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace s ys tem, hence the passing of the Reform Act. Grantin g my , Richard O.Oexmann ’

s, exemption reque st furthers the public interest through academic/visual awareness of the geographic al benefits in and around the NE Florida area. My ultra light weight s UAS is battery powered an d creates no emissions that can harm the environment. The consequence of my

ultra light weight s UAS crashing is far less than a full size helicopter or fixed wing aircraft ; which are heavy , contain combustible fuel and can
cause catastro phic devastation to the public. Utilizing sUASs mi nimizes the requirement for c onventiona l airc raft. Thi s eliminates the need for an on board pilot, time consumin g adherence to regulations s urroundin g bookkeeping and s ubmi ss ion of flight path s to l ocal civilian or military airports, and detrime ntal effec ts to the environment caused by operating a co mbustibl e fuel based, l arge sca le aircraft, with res tri cti ons on the proximity
to the targe t for remote sensing.

F li ght Capabilitie s an d Charact eris tic s of Richard O. Oexmann s UAS s Pursuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by

the overall capabilities and characteristics of the sUAS. Richard O. Oexmann UAS s utili zes four (4) rotating 9 inch plastic propellers paired oppositely to each other for balance, control and stability

. The total s pan of the sUAS i s less than 1.2 m a ll owing for stabl e flight or l anding even with the sudden onset of d etrime ntal e nvironmenta l conditions. Richard O. Oexmann sUAS is designed to prim arily hover in place to cap ture photographic data and then operate at l ess than a 35 knot maximum sp eed to th e n ext point of interest. They are capable of verti cal and horizontal operations but, in practice, is operated only wi thin VLOS by

the PIC. **In addition**  **the PIC,**  **Richard O. Oexmann is a licensed ATP Multi Engine**  **Commercial SEL, Rotorcraft**

**- Helicopter rated Pilot with a current**  **medical and with current flight hours having an impeccable safety record.** 

The flight zone will restricted to operators and safety observers to minimize pedestrian access in the flight zone of the client's grounds. In the event of loss of visua l of the UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r, a ,h) based controls which a ll ows the PIC to utilize one controller axis to recall the UAS to the PIC's position without concern to the current heading of the sUAS. In the event of loss of sight of the sUAS into an area co ntaining hazards or possible hazards, the spotter ha s a heads up display containing a live video feed which can be used to locate the UAS wh il e it maintains it's position in hover mode. The sUAS has demonstrated it's ability to maintain it's position by

GPS coordinates in hover mode in 25 kts or greater wind gusts at rvr less than 25 feet representing an extreme environmental condition be yond the range of condi tions within the scope for sUAS operation. All of Richard O. Oexmann’s sUASs utilize LiPo (lithium polyme r) battery based power sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flight times generally

last between eight (8) to ten (1 0) minutes allowing the staff to work with small flight areas per phase. The maximum flight time without payload is 25 minut es, however practical safe operation limits this to 10 to give amp le time to control the sUAS to a safe landin g zone. Richard O. Oexmann further restricts flight time by not operating it’ s sUASs with less than twenty five percent battery capacity

. Further safetymanagement sy stems i n place include a GPS mode that allows Richard O. Oexmann ’s

sUAS to hover in place if communication with the PIC is lost and optionally follow a set of way points at a set speed and height to a 'home base' predesignated safe l anding zone. In the event of un foreseen motor(s) failure, the sy stem will enter into a controlled descent while allowing full use of all UAS flight controls by the PIC. All commands sent via remote controller received during a controlled descent are translated to an 'as meant' paradigm meaning the flight control pa ckage will use it's real time 3 dimensional position and compensate rotors control the sUAS regardless of spin velocity

. This assures that if one sy stem is compensate d a safe and successful landing can still occur.

I V. Reasons W hy an Exempti on to Richard O. Oexmann W i ll Not Adversely Affect Safety Standards Richard O. Oexmann contends that operation of it's sUASs will not "create a hazard to

users of the national airspace sy stem or th e public:' as stated in 112 P.L. 95 §333 (b). Given the diminutive size and weight of Joseph D. Renda sUASs, combined with their operation in cordoned off and well controlled areas, Richard O. Oexmann’s sUASs falls within Co ngress's contemplated safety zone. Richard O. Oexmann’s s UASs have an established safety record bolstered by m ultipoint Preflight check li st, awareness of their surroundings and intimate knowledge of the behavior of the sUAS platform in many weather conditions. This safety record and impl em ented operational pra ctices demonstrate an awareness of public safety

. Richard O. Oexmann ’ s operations routinely provide a level of safety

at least equal to existing rules, and in nearly every instance, exceeds existing rules. Richard O. Oexmann does not operate its UASs on or near airports and generally has only operated on private grounds with cor doned off areas or areas under the control of the property owner I client

. Richard O. Oexmann determines the areas needed to fulfill the clients ' goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially by the RC UAS trade and hobby groups and recently codified by relevant FARs. Richard O. Oexmann ’

s standardized on the foll owing practices to ensure safe operation of it's UASs:

• Work wi th onsite personnel to plan the flight goal s,

• Work with onsite personnel to restrict access to non esse ntial persons,

• Operation by unaided VLOS operation only

, ● Operation in phases 10 minutes in length

● Operation to minimal 25% battery power
● Operation of d evi ce to GPS aided readout to 39 0 ft at maximum, Nume rous pre programmed fail safes that ensure specific be havior per i ssu e
● Preform a site check day(s) before flight t o identify pot enti al issues, Subscribe to relevant local weather and safety al erts,

● Expertly

choose data collection in strum ents and accessories to minimize flight requirements or expertise,● Richard O. Oexmann has experi ence in similar fields and has ad apted this experience

in it's use of UASs to increase safety

. In co mbination to th e ever expanding knowledge from hobbyist s and experts alike, Richard O. Oexmann i s constantly evolving it 's practice s when there is a clear benefit to ope ration s or increas ed safety el em ent.

**A. Summary** Pursuant t o 14 C.F. R. Part 11
, the following summary i s provide d for publication in the Federal Register, sho uld it b e d etermin ed that publication is needed: Richard O. Oexmann (applicant) seek s an exemption from the fo llowin g rul es : 1 4 C.P.R. §2 1, s ubpart H ; 1 4 C.F.R 45.23(b) ; 14 C.F .R. §§61.113( a) & (b) ; 91.7 (a) ; 91.9 (b) (2) ; 9 1.1 03{b) ; 91.109; 91.119 ; 91.121; 91.151(a); 91.203(a) & (b) ; 91.405 (a); 91.407 (a) (1 ) ; 9 1.4 09 (a) (2) ; 91.409 (a) ( 2) and 91.417 (a) & (b) to operate commercially a small unmanned ve hicle (11 kg or less) in elevated photographic and remo te sensing operati ons . Approval of exemptions allow in g commercial operation s of sUASs in the the media indu stry will e nhan ce safety by reducing risk associated with conventional aircraft operations and othe r means of elevated remote sensing involving persons. The public benefit served by

approval of this petition i s increased awareness o f characteri stics of difficult imag ing targets. A sUAS wei ghing fewer than 11 kg and powered by sealed batteries eli minates virtually all associate d risk inherent in operating convention al aircraft in close proximity

to buildings or persons or otherwise elevating persons to a position the y would be able t o collect needed dat a. The operation of sma ll UASs, weighing less than 55 lbs., co ndu cted in the stric t conditions outlined above, will provide an equival e nt le vel of safety supporting the grant of the e xemptions requested herein, including exempting the app li cant from the requirements of Part 21 and a llowing c omm erc ial operations. As identified and described herein, Richard O. Oexmann is an experienced licensed ATP Multi Engine, Commercial SEL, Rotorcraft

- Helico pter rated Pilot certificate # 1645002 for over 50 years presently living in Florida ; Also experienced in flying Unmanned Aircraft Sy stems (U. A.S) for recreational purposes. Reco gnized by the community

as a professional realtor experienc ed in the various photographic industries. Mr. Oexmann has a spotless safety

record with over 17,000 flight hours of which over 15,000 were NBAA Safety

Award . 800 of those hours were in U.S. Army helicopters inc luding a combat zone (Viet Nam), and as a BellSouth Corporate Aviation Falcon 900EX Captain was one of the first to be certified to fly into and out of KDCA after 9/11 as a Corporate Aircraft Captain for BellSouth. The FAA has b een given the authori ty t o i ssu e the exemption to Richard O. Oexmann pursuant to the Federa l Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek
yo ur consideration and approval of this petition.**VI. Emergency**  **Pr oce**  **du r** **es** • Loss of Remote Signal

The flight package feature s an optional enhanced failsafe which returns the UAS to the h om e base way point via the same path taken to point of lost signal. The UAS will then perform a hover over this way point and then a contro ll ed landing.

• Loss of GPS signal The sy stem will operate in GPS assi sted mode with three (3) satellites. At l oss of three (3) GPS satellites, manual mode can be activated or the flight package can be programmed to perform a controlled landing to the home base way point. Ground based height ranging is perf ormed by a separate sy stem and so l oss of GPS wi ll not impact controlled landing in a safe manner.

• Loss of Engine Power In the event of one (1) (or to two oppositely positioned) rotor or motor failure the
sy stem will enter into controlled spin where all controls are trans l ated based on current orientation and will behave as normal operation to the PIC to ensure a safe l anding, In the event of multiple rotor or motor failures the flight package can be configured to perform a safe l anding or attempt operati on to home base way point. Note : Behavior of the landing location is highly dependent on the position and number of rotors/motors that are affected.

• Loss of Ground Control Software This w ill not affect operation of the flight. The unit will be piloted to a safe l anding area and then l anded so that examination of the link can be made.

DJI Phantom Info : http://www.dji.com/product/phantom2v ision/ spec Phantom 2 Vision User Manual (EN) v1.8 Phantom 2 Vision Pilot Training Guide (EN) v1.1 Smart Flight Battery

Safety Guidelines (EN, FR, DE and JP) Phantom 2 Vision Quick Start Guide (EN) http://dow nload.dji

- innovations.com /dow nloads/nazam

- v2/en/NAZA

M_Quick_Start_Guide_v1.26_ en.pdf