January	3,	2016

**Name	and	Address	of	Petitioner:** David	Weldon	Hillmyer 1820	Meadowood	St. Sarasota,	FL	34231 941

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- 5901 dhillmyer@mac.com Dear	Sir	or	Madam, Pursuant	to	Section	333	of	the	FAA Modernization	and	Reform	Act	of	2012	(the "Reform	Act")	and	14 C.F.R.	Part	11, David	W	Hillmyer, the	Petitioner,	request exemption	from	the	following	Federal	Aviation Regulations	in	order	to	legally operate	an	Unmanned	Aircraft	System	(UAS)	in	the	National Airspace System. **Regulations	from	which	the	exemption	is	requested:**
14CFR	21	H 14	CFR	45.23	(b) 14	CFR	91.7	(a) 14	CFR	91.9	(b)(2) 14	CFR	91.103	(b) 14	CFR	91.109 14	CFR	91.119 14	CFR	91.121 14	CFR	91.151	(a) 14	CFR	91.203	(a)	&	(b) 14	CFR	91.405	(a) 14 CFR	91.407	(a)	(1) 14	CFR	91.409	(a)	&	(b) 14	CFR	91.417	(a)	&	(b) **Reason	and	extent	of	relief	r equested:**  Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14 CFR	Part	11,	David	W	Hillmyer,	the	petitioner and	operator	of	Unmanned	Aircraft Systems(UAS), reques ts	relief	from	the	listed regulations	in	order	to	operate	an	UAS for	the	following professional/ commercial	purposes:
1. Aerial	p hotography and	videography	of	real	estate	for	marketing	purposes. 2. Aerial	ph otography	and	videography	of	private	events,	such	as	weddings,	and other	private	social	events. 3. Aerial	p hotography and	videography	of	marine	sporting	events,	such	as sailing	and	rowing	regattas. 4. Other	profession	activities	related	to	aerial	photography	and videography.**Reasons	why	granting	this	request	would	be	in	the	public	interest:**

The	Petitioner	believes	the	use	of	the	UAS's	is	more	economical	and	safer	to	use	for the	aforementioned purposes.	Use	of	the	UAS	rather	than	a	manned	aircraft	is	more economical	to	the	consumer,	and beneficial	to	the	general	public	due	to	its	small size,	low	noise, and	minimal	potential	for	accident. **Reasons	why	granting	the	exemption	would	not	adversely	affect	safety:** Given	the	small	size	of UAS’s	an d	the	controlled environment	they	are	operated	in, safety	is	enhanced	when	compared	to	manned	aircraft	operations	for	similar purposes.	UAS’s	carry	no	combustible	fuel	or	human	life	onboard,	thus	greatly reducing	the	chance	of	significant	property	damage	or	potential	for	l oss	of	life	in	the event	of	an	unsuccessful	flight.	For	these	reasons,	granting	this	exemption	request would	not	adversely	affect	safety. Additionally,	the	requestor	is	an	active commercial	airline	pilot,	holding	an	Airline	Transport	Pilot	Certificate.	The requestor	is	very	familiar	with	safety	protocols	and	practices	involved	in	the	safe operation	of	aircraft. **Summary:	(specific	exemptions from	14	CFR**  **and	reason	for	relief	requested):** 21	H	(Airworthiness	Certificates) Given	the	size,	weight,	and	limited operating	area	associated	with	UAS	operations,	I feel	and	from	this	requirement	exemption	is	warranted	and	would	not	comprise safety. 45.23	(aircraft	markings) Given	the	small	size	of	the	UAS,	the	markings	described	in	this rule	cannot reasonably	be	affixed	to	the	UAS.	The	UAS	will	have	affixed	to,	in	a	prominent location,	the	UAS	Registration	Number,	as	required. 91.7(a)	(airworthiness) Because	an	airworthiness	certificate	is	not	applicable	to	UAS	operations,	this regulation	does	not	apply. 91.9(b,	2) (flight	manual	requirements) Relief	from	this	requested	due	to	the	fact	that	flight	manuals	cannot	be	carried onboard	the	UAS.	In	lieu	of	this	regulation,	the	operator	will	have	available	the ground	based	control	station, all	applicable	flight	manuals. 91.103(b)	(preflight	action) Relief	is	requested	from	this	regulation	because	the	UAS:Will	not	be	operated	from	or	require	the	use	of	runways,	takes	off	and	lands

vertically,	and	will	not	carry	onboard	a	flight	manual.
91 .109	( flight	instruction) This regulation	provides	that	"No	person	may	operate	a	civil	aircraft	that is being used	for	flight instruction	unless	that	aircraft	has	fully	functioning	dual	controls." Reason	for	Exceptio n	is	UAS's	are remotely	piloted aircraft,	by	their	design	so	not have	fully	functional	dual	controls.	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	pilot	nor	passenger will	be	carried	in	the	aircraft	and	by	the small size	and low	flight speed	of	the aircraft. 91.119	(minimum	safe	altitudes) The	regulation	provides that	over	sparsely	populated	areas	the	aircraft	cannot	be operated	closer	than 500	feet	to	any	person,	vessel,	vehicle,	or	structure.	Since	the aircraft	will	be	operating	at	a	maximum	of 400	feet	AGL, this	requirement	can	not apply.	The	reason	for	ex e m ptio n request	is	the	use	of	UAS	will	be	flown	no	higher than	400	feet	AGL	i n	line	of	sight	over	developed	and	developing residential	areas that	may	be	considered	congested	areas

. That	will	not	always	be	the	case	when providing	a	'Property	Survey ' flight	becaus e	they	could	be	conducted	over	empty lots	or	acreages	with no	structures.	In	the	case	of	flying	over	or	near	existing	private property	while	providing	aerial	imagery, property	inspections,	and	property assessments,	landowners	will	be	notified by	the	UAS	op erator. 91.121	(altimeter	setting) This	section	requires	that	each	person	operating	an	aircraft	shall	maintain the cruising	altitude	or	flight level	of	that	aircraft,	as	the	case	may	be,	by	reference	to	an altimeter	that	is	set,	when	operating	below18 ,000	feet	MSL. Reason	for	Exc eption is	that UAS	do	not have	a	barometric	altimeter.	It does	have	a GPS	that	will	calculate	altitude.	The Petitioner	will	limit	flights	to	a	maximum altitude	of	400	feet	AGL	as	granted	in	Exemption	No.	11623,11664,	and	11734. 91.151(a)	(fuel	requirements) Fuel	requirements	for	flight	in	VFR	conditions:	(a)	No	person	may	begin	a flight	in an	airplane	under	VFR conditions	unless	(considering	wind	and	forecast	weather conditions)	there	is	enough	fuel	to	fly	to	the first	point of	intended	landing	and, assuming	normal	cruising	speed.	(1)	During	the	day,	to	fly	after	that for	at	least	30 minutes. Reason	for	Exception : The	UAS	provides	a	low	battery	warning	to	indicate when	you	should	return	the	UAS	to	the	launch	point. In	addition,	a	"low"	and "critical"	battery	level	warnings	and	implemented	a	"return	to	Home"	(or	"Goland")	action	in	these	situations.	The	Petitioner	will	not	initiate	a	flight	unless

(considering	wind	and forecast	weather	conditions)	there	is	enough	power	to	fly	at normal	cruising	speed	to	the	intended landing	point	and	all	flights	will	be conducted during	daylight	hours.
91.203	(a)	&	(b): ( Carrying	Civil	Aircraft	Certification	and	Registration) This	regulation	provides	as	follows: No	person	may	operate	a	civil aircraft	unless	it has	an	appropriate	and	current airworthiness	certificate. Reason	for	exception	to this	requirement	is	that	UAS	do	not	require	an	Air	Worthiness	Certificate. 91.405(a)	(maintenance	requirements) Each	owner	or	operator	of	an	aircraft

- ( a)	shall	have	that	aircraft	inspecte d	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. Reason	for	Exce ption : The	Petitioner will inspect	the	aircraft	prior	to	every	flight.	The	Petitioner	also	will	follow	the Manufacturers’ recommended	preflight	checklist	and	make	any	repair	necessary before	flights	occur. The	Petitioner	will	also	maintain	a recorded	log of	maintenance repairs	performed

. 91.407	{a)	{1): (m aintenance ) Operation	after	maintenance,	preventative	maintenance,	rebuilding	o r	alteration: (a)	No	person	may operate	any	aircraft	that	has	under	gone	maintenance, preventative	maintenance,	rebuilding,	or alteration	unless	(1)	it	has	been	approved for	return	to	service	by	a	person	authorized	under	43.7	of	this chapter. Reason	for	Exception:	The	p etitioner will	adhere	to the manufactures	suggested replacement	parts. 91.409	(a)(l	and	2):	(i nspections ) Inspections:	(a)	Except	as	provided	in	paragraph	(c)	of	this	section,	no person	may operate	an	aircraft unless,	within	the	preceding	12	calendar	months,	it	has	had	(1) an	annual	inspection	in	accordance	with part	43	of	this	chapter	and	has	been approved	fo r	return	to	service	by	a	person	authorized	by	43.7	of this	chapter;	or	(2) An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	accordance	with part 21	of	this	chapter.	No	inspection	performed	under	paragraph	(b)	of	this	section may	be	substituted	for any	inspection	required	by	this	paragraph	unless	it	is performed	by	a	person	authorized	to	perform annual	inspections	and	is	entered	as an	"annual"	inspection	in	the	required	maintenance	records. Reason	for	Exception The	Petitioner	will	follow	man ufacturer's guidelines to	ensure	that	the	UAS	is	in	a condition	for	safe flight	at	all	times.91.417	(a)	&	(b): (maintenance	r ecords )

Except	for	work	performed	in	accordance	with	91.411	and	91.413	each	registered owner	o r	operator shall	keep	the	followin g	records	(l)(i)	(ii)(iii) (2)(i)(ii)(iii)(iv)(v)(vi)	for	the	periods	specified	in	paragraph	(b) of	this	section:	(	1) (2)	(3). Reason	for	Exception : The	Petitioner	will	keep	a	record	of	all	repairs	and modifications.	The	Pe titioner	will use only the manuf acturer s’ approved parts	for	all repairs	and	modifications. **Conclusion:** The	petitioner,	David	W	Hillmyer,	feels	that	granting	these	requests	and	exceptions will	be	in	the	best	interests	of	all	concerned.	The	use	of		UAS	greatly	reduces	the potential	for catastrophic	damage	and	injury	that	may	result	from	the	using conventional	manned	aircraft	for	the	purposes	listed	in	this	request. Best	Regards, David	W.	Hillmyer