Cameron T. Goetzel Aug 01, 2015

324 Heritage Oaks Dr. Eugene OR, 97405 707

- 596

- 0062 (Cell) cameron95492@gmail.com US 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 of 2012 References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the petition of DOUGLAS TRUDEAU
In accordance with the FAA Guidelines for Submitti ng a Petition for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012, I , Cameron T. Goetzel, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§
**61.113 (a); 61.113(b); 91.119(c); 91.121; 91.103(b)(1), (b)(2)**  In order to operate small unmanned aircraft s ys tems (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography , crop survey ing, mapp ing, inspections and other flight operations that could be performed safel y and more cost effective than manned aircraft, the petitioner would like to apply for an exemption from the above mentioned Code of Federal Regulations (CFR). Operations would only be conducted under the request and permission of clients or their authorized agents. Conditions outlined herein or as may be established b y the FAA would be followed during all operations. The Petitioner seeks exemption from the above mentioned Federal A viation Regulations for the following reasons; **61.113 (a) & (b)** ; While helpful, a Private Pilots License will not ensure remote control piloting skills. An equivalent level of safet y can be achieved by an y pilots (PIC) operating under this exemption becau se the petitioner’s UAS does not carry pilots or passengers. The risks of operating a sUAV, which weighs less than 3 lbs. and utilizes fuel that is not combustible, are far less than those associated with commercial activities outlined in 14 CFR part61. Th e petitioner has alread y explored earning a Recreational Pilots Certificate, and would begin education and eventual certification at the direction of the FAA. **91.119 (c)** ; As discussed in Exemption 11138 (DOUGLAS TREDEAU) operations conducted closer than 500 feet to the ground may require the UA to be closer than 500 feet to essential persons or objects. The petitioner requests exemption or modification and clarification to theterms “congested areas” and “densel y populated”. The petitioner requests this exemption to

allow responsible operations within subdivisions and neighborhoods.
**91.121** As discussed in exemption 11138 (DOUGLAS TRUDEAU) is not applicable since UAS does not use an altimeter. I nstead the UAS will utilize on electronic Global Positioning Sy stem (GPS) for altitude information. **91.103 (b)(1), (b)(2)** If granted the petitioner agrees to additional safet y procedures, but not limited to: 1. Operating the UAS within a radius of 1000 feet from the ground station. 2. Maximum flight times of 9 minutes. 3. Operate only

within visual line of sight (VLOS) 4. Use the UAS GPS safet y feature to maintain controlled, and stable flight in the case of a RC communication interruption. 5. Post wa ring signs reading: “Attention Aerial Photograph y in Progress” 6. Constantly

monitor telemetry

feeds. 7. Contact respective airports within 5 miles of operation and inform them of flight time, flight duration, flight plan elevations , and an y other pertinent information. 8. Have procedures in place to abort flight plans in the interest of safety

. 9. Follow pre

- flight check, maintenance, and overhaul procedures recommended by the manufacturer. 10. L ogs contain ing UA flight time, incident, accident, and parts replaced will be recorded, and made available to the FAA.

**The DJI Phantom 3 Advanced**
The DJ I Phantom 3 Adv anced is among the highest quality of small battery

powered hobb y grade quadcopters. It is equipped with four rotors which are driven by electric motors that utilize self

- tightening propellers. I t has a fl yi ng weight of 1280 grams and is primarily designed to carry 1080p HD camera. Its maximum horizontal fly ing speed is 35MPH, its maximum ascending speed is 13MPH, and its maximum descending speed is 8MPH. I t utilizes an internal inertial measuring unit (IMU) augmented with GPS to maintain its position and g eospatial orientation. I t is controlled primarily

with a FCC approved radio control (RC) sy stem. Real time video, telemetry information can be transmitted down to the ground control and PIC to allow monitoring of battery

level, altitude, distance from PI C, and GPS signal strength. It has failsafe modes for either RC signal loss or GPS signal loss. I t has a maximum flight time of approximately

23 minutes with expected flight times of less than 10 minutes.

**Public Interest** Use of UAS instead of manned airc raft would enhance safet y and reduce the environmental human footprint compared to similar activities conducted with manned aircraft. Aerial photograph y is a valuable marketing and inspection tool and can help ensure our econom y’s growth through efficiency , and accurate representation. Crop survey ing with UAS can helpreduce the use of pesticides, help conserve water, as well as increased crop yields. Liability

insurance with obtained after exemption request is granted.