Date: October	4,	2015

U.	S	.	Department	of	Transportation	Docket	Management	System 1200	New	Jersey	Ave.,	S	E Washington, DC	20590	_ Filed	by:	Gerald	Thielemann 4371	Nassau	Way	N.E. Marietta,	GA.,	30068
Petition	of Gerald	Thielemann for	Exemption	Pursuant	to	section	333. of	the	FAA	Reform	Act

. To	whom	it	may	concern, Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the Reform	Act)	and	14	C.F.R.	Part	11, Gerald	Thielemann,	airman	(certificate	number 3287888) , operator	of	Small	Unmanned	Aircraft	Systems	(sUASs)	equipped	to conduct	aerial	photography	and	videography,	hereby	applies	for	an	exemption	from the	listed	Federal	Aviation	Regulations	("FARs")	to	allow	commercial	operation	of its	sUASs,	so	long	as	such	op erations	are	conducted	within	and	under	the	conditions outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by	Section	333.1
Gerald	Thielemann has	been	in the	TV/Movie business	since	2010. I	have	been	a private	pilot	since	09/15/1987	and	a	comm ercial	pilot	since	01/24/89. I	have	been flying	remote	control vehicles on	a	recreational	side	for	many	years	and	would	like to	bring	the	capabilities	of	a	UAS	to	my	photography	business. As	described	more	fully	below,	the	requested	exemption	would	permit	the operation	of	small,	unmanned	and	relatively	inexpensive	sUAS	under	controlled conditions	in	airspace	that	is	1. Limited 2. Predetermined and	3. Controlled .	The proposed	exemption,	if	granted,	would	allow Gerald	Thielemann to	conduct commercial	operations	of	small,	unmanned	aircraft	systems	("UAS")	meeting	or exceeding	all	of	the	operational	and	safety	requirements	Congress	has	set	forth	in Section	333.
Gerald	Thielemann is	an	independent	photographer	and	videographer	that	does work	for	multiple	clie nts	and	plans	to	exploit	the	capabilities	of	Unmanned	Aerial Systems	to	offer	a	multitude	of	services,	including:

- Aerial	surveying

- Remote	sensing

- Agricultural	support

- Real	Estate	Photography

- Aerial filmmaking and	photography

- Construction	site	i nspections	and	monitoring

- Wildlife	and	forestry	monitoring

- Educational	and	research	operations Statutory	Authority	Section	333,	titled	"Special	Rules	for	Certain	Unmanned	Aircraft Systems",	provides	a	mechanism	for	seeking	expedited	FAA	authorization of	safecivil	UAS	operations	in	the	NAS.	Section	333(a)	states	that	the	FAA	"shall	determine

if	certain	unmanned	aircraft	systems	may	operate	safely	in	the	national	airspace system	before	completion	of	the	(comprehensive)	plan	and	rule	making	required	by s ection	332(b)(1)	of	this	Act	or	the	guidance	required	by	section	334	of	this	Act."	In Section	332(b)(1	),	Congress	made	it	clear	that	Section	333	provides	a	mechanism for	"expedited	operation	authorization"	if	several	factors	are	met.	Petitioner	meets all requirements	to	permit	FAA	approval	of	commercial	UAS	operations. The	Petitioner	Requests	Relief	From	the	Following: Regulations	from	which	the	exemption	is	requested:
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 14C.F.R.	(91.401

- 91.417) Unmanned	Aircraft	System	sUAVs	are	oftentimes	seen	as	superior	to	helico pters	due to	the	smaller	devices	cheaper	equipment	and	personnel	cost,	reduced	noise	and	as such,	a	much	smaller	environmental	impact	which	promotes	public	safety.	· We	are	petitioning	for	exemption	to	enable Gerald Thielemann authority to	use	the DJI	Phantom	3	Professional,	DJI	Phantom	3	Advanced	DJI	Phantom	2, and DJI	Inspire	1, all	of	which	have	been	previously	approved	by	the	FAA	in	past	grants	of	exemptions, for TV/Movies and	to	limit	operations	to	less	than	60	miles	per	hour	and	away	from airports. Th e DJI	Phantom	3	Professional,	DJI	Phantom	3	Advanced	DJI	Phantom	2,	and DJI	Inspire	1 are equipped	with	a	three

- axis	gimbals and	using	High

- Def. cameras. These sUAVs	have a built

- in	capability	to	limit	the	height	it	flies	above	the	ground,	to limit	the	radius	of	the	distance	it	flies	from	the	operator	and	to	exclude	it	from	Class 8,	C	and	D	airspace	including	a	no

- fly	zone	feature.	The DJI	Phantom	3	Professional, DJI	Phantom	3	Advanced	DJI	Phantom	2,	and	DJI	Inspire	1 also	have the	fail	safe function	of	the Naza

- M	autopilot	system	which	means	when	the	communication between	the	Main	Controller	and	the	transmitter	is	disconnected,	the	outputs	of	all command	sticks	from	controller	will	go	to	the	center	position.	If	the	GPS	signal	is good	enough,	the	system	will automatically	trigger	Return	to	Home	and	will land safely.	The	above	specifications	meet	with	the	Model	Aircraft	Operating	Standards as	set	below:

 Gerald	Thielemann will	only	operate	its	sUAS	in	line	of	sight	of	a	pilot	and/orobserver	and	will	operate	at	sites	that	are	a	'sufficient	distance'	from populated	areas	within	the	sterile	area	described	in	the	FOPM.	Such operations	will	insure	that	the	sUAS	will	"not	create	a	hazard	to	users	of	the national	airspace	system	or	the	public."

 When	flying sUAVs with in	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	20	minutes.	Flights will	be	terminated at	25%	battery	power	reserve	should	that	occur	prior	to the	20	minute	limit.

 The sUAVs 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.

 Minimum	crew	for	each	operation	will	consist	of	the	sUAS	Pilot,	and	Visual Observer.

 The	sUAS	operated	by	the	petitioner	weighs	less	than	55	pounds,	including the	payload	(i.e.	camera,	lens,	and	gimbal)	.

 The sUAVs will	operate	at	speeds	of	no	more	than	50	knots,	can	hover,	and can simultaneously	move	vertically	and	horizontally	.

 Given	the	small	size	of	the	sUAS	and	the	restricted	sterile	environment within	which	they	will	operate,	our	sUAS	operations	adhere	to	the Reform Act's	safety	requirements.
The	UAs,	powered	by	batteries,	is	smaller,	lighter	and	more	maneuverable	than larger	aircraft	running	on	combustible	fuel,	it	operates	at	lower	altitudes	with	no people	on	board	and	will	thereby	reduce	current	risk	leve ls	and	thereby	enhance safety	and	diminish	the	likelihood	of	death	or	serious	bodily	injury.	With	a	small payload	and	maximum	flight	time	of	only	20	minutes,	this	is	offers	little	or	no	risk	to national	security,	personal	property,	or	larger	aircraft.	Low	level	oblique	photos	and video	from	several	angles	are	far	more	effective	than	ground	based	imagery	for displaying	the	characteristics	of	large,	complex	properties	with	several	buildings· and	large	trees.	The	applicants	in	the	past	have	chartered	2

- s eat	full

- sized helicopters	for	this	purpose,	which	has	proven	more	costly	than	many	potential clients	have	been	able	to	afford.	The	benefits	of	reduced	cost	and	improved	quality of	presentation	from	the	UA	will	be	valuable	to	and	benefit	many	buyers	and	se llers of	real	property.	Additionally,	we	request	that	we be	allowed	to	use	our	system	to film	for	marketing	and	promotional	materials	for	clients	on	their	own	private property	within	a	200	feet	AGL. (a)	No	flight	will	be	made	with	a	Gross	weight	exceeding 55	pounds; (b) AII	operations	must	occur	in	FAA	Class	G	airspace	at	no	more	than	400	ft	AGL,	at an	airspeed	of	no	more	than	25	knots	and	no	further	than	1/8th	NM	from	the	PIC; (c) AII	operations	must	utilize	a	visual	observer	(VO).	The	VO	and	PIC	must	be able to	communicate	by	voice	at	all	times	during	a	flight	operation;(d) Operations	will	be	restricted	to	flights	over	private	property	with	the	permission

of	the	property	owner; (e)	All	required	permits would be	obtained	from	state	and	local	government	prior	to operation; (f) Gerald	Thielemann,	will	not	be	operate	over	densely	populated	areas; (g) Gerald	Thielemann,	will	not	be	operating	over	any	open

- air	assembly	of people; (h) Gerald	Thielemann,	will	not	be	operating	over	heavily	tracked	roads; (i) Geral d	Thielemann,	will	not	be	operating	within	5	NM	of	an	airport	or	heliport without	prior	permission. We	respectfully	request	exemption	under	Section	333	to	enable Gerald	Thielemann, to	operate	efficient,	limited,	low

- risk	commercial sUAVs	operation for	the activities stated	respecting	at	all	times	the	space	and	privacy	of	citizens	and	property	whilst keeping	our skies	safe. Sincerely, Gerald	ThielemannEXEMPTION	REQUESTS	AND	EQUIVALENT	LEVEL	OF	SAFETY

Gerald	Thielemann requests	an	exemption	from	the	following	regulations	as	well	as any additional	regulations	that	may	technically	apply	to	the	operation	of	the sUAVs System: 14	CFR	Part	21,	Airworthiness	Certificates This	part	establishes	the	procedures	for	the	issuance of	an	airworthiness	certificate. While	the FAA	continues	to	work	to	develop	airworthiness	standards	for	Unmanned Aerial	Systems,	we request	an	experimental	certificate	be	issued	for	the DJI	Phantom 3	Professional,	DJI	Phantom	3	Advanced	DJI	Phantom	2,	and DJI	Inspire	1 under	either or	both	of	the following	provisions: 21.191	Experimental	certificates.	Experimental	certificates	are	issued	for	the following	purposes: (a)	Research	and	development.	Testing	new	aircraft	design concepts,	new	aircraft	equipment, new	aircraft	installations,	new	aircraft	operating techniques,	or	new	uses	for	aircraft. (b)	Showing	compliance	with	regulations.	Conducting	flight	tests	and	other operations	to show	compliance	with	the	airworthiness	regulations	including	flights to	show compliance	for issuance	of	type	and	supplemental	type	certificates,	flights to	substantiate	major	design changes,	and	flights	to	show	compliance	with	the function	and	reliability	requirements	of	the regulations.	Since	the	experimental certificate	can	be	us ed	for	commercial	purposes	such	as market	surveys,	sales demonstrations,	and	customer	crew	training,	we	would	expect	that	an experimental certificate	would	permit	our	commercial	purpose	as	well.	The	aircraft	will	not	carry persons	or	property,	will	not	carry	fuel,	and	will	only	fly	under	strict	operational requirements.
Combined	with	the	UA's lightweight,	being	constructed	primarily	of	carbon	fiber and	plastic,	we propose	that	the	UA	will	be	at	least	as	safe,	if	not	safer,	than	a conventionally	certificate d aircraft	performing	the	same	mission.	If	an	experimental airworthiness	certificate	is	not appropriate	for	this	application,	then	we	request	an exemption	of	14	CFR	Part	21,	Subpart	H. and	the	requirement	for airworthiness certificate	in	general. Citing the	equivalent	level	of safety	outlined	in	the	previous paragraph. 14	CFR	45.23	Display	of	marks;	general	and	45.29	Size	of	marks. These	regulations	provide that	each	aircraft	must	display	"N"	and	the	aircraft's registration	number	in	letters	at	least 3 inches	high.	Additionally,	the	aircraft	must display	the	word	"EXPERIMENTAL"	in	letters	at	least 2	inches	high	near	the entrance	to	the	cabin,	cockpit,	or	pilot	station.	The sUAVs	do not	have an	entrance	inwhich	the	word	"EXPERIMENTAL"	can	be	placed,	an d	may	not	have	a registration

number	assigned	to	it	by	the	FAA.	We	propose	to	achieve	an	equivalent	level	of safety	by	including	the	word	"EXPERIMENTAL"	in	the	placard	on	the	top	of	the aircraft,	as shown	above,	where	the	PIC	(Pilot	In	Control),	VO	(Visual Observer)	and others	in	the	vicinity	of the	aircraft	while	it	is	preparing	for	launch	will	be	able	to see	the	designation.	Additionally,	we feel	that	the	permanent	placard	discussed	in the	previous	paragraph	will	provide	the	aircraft's registration	inform ation	at	the ground	station.	Finally,	we	will	display	at	the	ground	station	a	high contrast	flag	or banner	that	contains	the	words	"Unmanned	Aircraft	Ground	Station"	in	letters	3 inches	high	or	greater.	Since	the	aircraft	will	operate	within	3/4	NM	of	the ground station,	the banner	should	be	visible	to	anyone	that	observes	the	aircraft	and chooses	to	investigate	its point	of	origin. 14	CFR	61.113	Private	pilot	privileges	and limitations Pilot	in	Command	and	61.133 Commercial	pilot	privileges	and	limitatio ns. The	regulation	provides	that	no	person	that	holds	a	Private	Pilot	certificate	may	act as	pilot	in Command	of	an	aircraft	for	compensation	or	hire.	Subparagraph	(b) allows	a	private	pilot	to	act as	pilot	in	command	of	an	aircraft	in	connection	with any business	or	employment	if:	(1)	The flight	is	only	incidental	to	that	business	or employment;	and	(2)	The	aircraft	does	not	carry passengers	or	property	for compensation	or	hire.	Our	proposed	operations	require	that	the	PIC must	hold	at	least	a	Private	Pil ot	Certificate	issued	by	the	FAA	and	since	the	aircraft cannot carry	passengers	or	property,	we	feel	we	meet	the	intent	of	61.113 Subparagraph	(b)	even though	the	intent	of	this	application	is	to	conduct	a	business. 14	CFR	91.7	Prohibits	the	Operation	of	an	aircraft	without	an	airworthiness certificate.	As no	such	certificate	will	be	applicable	in	the	form	contemplated	by	the FARs,	this	Regulation	is inapplicable. 14	CFR	91.9	Civil	aircraft	flight	manual,	marking,	and	placard	requirements. This	regulatio n provides	that	no	person	may	operate	an	aircraft	unless	a	current, approved	flight	manual	is	in the	aircraft.	We	assume	that	the	intent	of	this requirement	is	to	ensure	that	flight	manual information	is	available	to	the	aircrew while	operating	the	aircraf t.	We	request	an	exemption	to this	requirement	since	the aircraft	is	not	only	too	small	to	carry	documentation,	the documentation	would	not be	available	to	the	crew	during	flight	operations.	To	obtain	an equivalent	level	of safety	and	meet	the	intent	of	91 .9,	we	propose	that	a	current,	approved	sUAS Flight	Manual	must	be	available	to	the	crew	at	the	ground	station	anytime	the aircraft	is	in,	or preparing	for,	flight. 14	CFR	91.109	Flight	Instruction;	Simulated	instrument	flight	and	certain	flight	tests
The regulation states, "No	person	may	operate	a	civil	aircraft	that	is	being	used	for flight instruction	unless	that	aircraft	has	fully	functioning	dual	controls."	The	sUAS System	ground	based control	station	consists	of	a	small	hand

- held	radio	transmitterand	while	it	does	not	offer	a second	set	of	"controls",	both	the	student	and	instructor

can,	and	will,	operate	the	single	set	of controls	simultaneously.	With	both	student and	instructor	having	"hands

- on"	the	controls	during flight,	we	feel	that	this technique	meets	the	intent	91.109	and	provides	an	equivalent	level	of safety.	· 91.119	Minimum	safe	altitudes:	General.	The	regulation	states	that	over	sparsely populated areas	the	aircraft	cannot	be	operated	closer	than	500	feet	to	any	person, vessel, vehicle,	or structure.	Since	the	typical	mission	of	the	sUAS	would	be photography	or	survey	of	persons, vessels,	vehicles	or	structures	it	would	be necessary	to	operate	closer	than	500	feet	to	the	items listed.	Operations	will	only	be flown	over	property	o r	persons	where	permission	has	been obtained	and	careful pre - planned	has	been	performed.	The	aircraft	will	be	operated	at	a	low altitude allowing,	if	a	power	unit	fails,	an	emergency	landing	without	undue	hazard	to persons	or property	on	the	surface.	There fore	we	maintain	that	due	to	the	small	size of	the	UAS,	the	hazard to	persons,	vehicles	and	structures	is	minimal	compared	to manned	aircraft,	which	should	be considered	in	granting	the	exemption.	· CFR	91.121	Altimeter	settings. The	regulation	requires that	aircraft	shall	maintain	cruising altitudes	by	reference	to an	altimeter	setting	available	within	100	NM	of	the	aircraft.	The	sUAS will	always	fly below	400	feet	AGL	and	will	not	need	to	maintain	cruising	altitudes	in	order	to prevent	conflict	with	other	aircraft.	An	Above	Ground	Level	altimeter	measurement above	the takeoff	point	is	transmitted	via	radio	from	the	sUAS	on

- board	computer	to the	d1splay	screen held	by	the	PIC,	providing	a	constantly	updated	AGL	readout. 14	CFR	91.151	Fuel	requirements for	flight	in	VFR	conditions. The	regulation	provides	that	no	person	may	begin	a	flight	in	an	airplane	under	day

VFR conditions	unless	there	is	enough	fuel	to	fly	to	the	first	point	of	intended landing	and	to	fly	after that	for	at	least	30	minutes.	We	fee l	the	intention	of	this paragraph	is	to	provide	an	energy reserve	as	a	safety	buffer	for	delays	to	landing. The sUAVs	battery operated	and	the	maximum duration	of	flight	from	a	single battery	charge	is	18	minutes	with	a	20%	reserve.	Since	the aircraft	will never	fly more	than	1/8	NM	from	the	point	of	intended	landing,	a	full	battery	charge at	launch will	ensure	that	we	meet	the	reserve	energy	requirement	of	this	paragraph.	We request an	exemption	to	the	word	"fuel"	and	ask	for	an	equivalent	interpretation with	the	word "energy". 14	CFR	91.203(a)	&	(b)	Civil	aircraft:	Certifications	required. The	regulation	provides	that	an	airworthiness	certificate,	with	the	registration number	assigned to	the	aircraft	and	a	registration	certificate	must	be	aboard	the aircraft.	Additionally, subparagraph	(b)	provides	that	the	airworthiness	certificate be	"displayed	at	the	cabin	or	cockpit entrance	so	that	it	is	legible	to	passengers	or crew."	At	a	maximum	gross	weight	of	5.3	pounds, the	sUAS	is	too	small	to	carrydocumentation,	does	not	have	an	entrance,	and	is	not	capable	of carrying

passengers	or	crew.	To	obtain	an	equivalent	level	of	safety	and·	meet	the	intent	of 91.203,	we	propose	that	documents	deemed	appropriate	for	thi s	aircraft	by	the	FAA will	be located with	the	crew	at	the	ground	control	station	and	available	for inspection	upon	request.	In order	to	identify	the	aircraft,	we	propose	that	the information	found	on	airworthiness	and registration	certificates	be	permanently affixed	to	the	aircraft	via	placard	containin g	the	following information	plus	the	word "EXPERIMENTAL"	to	satisfy	the	requirement	of
14	CFR	45.23. 14	CFR	Subpart	E	(91.401

- 91.417)

- Maintenance,	Preventive	Maintenance, Alterations

. The regulation	provides	that	the	operator	is	primarily	responsible for	maintaining the	aircraft	in	an airworthy	condition,	including	compliance	with	part	39	and	43. Paragraphs	91.407	and	91.409 require	that	the	aircraft	be	"approved	for	return	to service	by	a	person	authorized	under	43.	7" after	maintenance	and inspection.	It	is our	intention	that	the	PIC	perform	maintenance	and inspection	of	the	aircraft	and "be	authorized	to	approve	the	aircraft	for	return	to	service."	The PIC	will	ensure	that the	aircraft	is	in	an	airworthy	condition	prior	to	every	flight	and in	addition conduct detailed	inspections	after	every	two	hours	of	flight.	Maintenance	performed	by	the PIC is	limited	to	repairing	small	cracks,	replacing	a	propeller,	checking	electrical connections	and updating	software	and	firmware	for	the	on

- board	comp uter. The manufacturer	or	their	designated	repair	facility	will	perform	all	other	maintenance

. The	PIC	will	document	work performed	in	accordance	with	91.417.	We	feel	that	due to	the	size,	construction,	and	simplicity of	the	aircraft,	the	PIC	can	ensure	an equivalent	level	of	safety. Safety	and	Benefits	of	the	UAS Gerald	Thielemann will	be	using	the	UAS	in	a	variety	of	applications	that	generally require expensive	full

- size	manned	aircraft	to	complete.	Small,	light,	unmanned aerial	vehicles	offer myriad	b enefits	over	the	use	of	full

- sized	manned	aircraft	for electric	power	line	inspection, oil/gas	pipeline	inspection,	advanced	agriculture,	film and	still	photography,	just	to	name	a	few. Replacing	significantly	larger	manned aircraft	carrying	crew	and	flammable	fuel	with	small	UAS carrying	no	passengers	or crew	creates	a	much	greater	margin	of	safety	for	the	pilots	and	crew. By	granting Gerald Thielemanns requested	exemptions,	the	FAA	will	help drive development	of safe	and	successful	commercial	UAS	operatio ns	and	will	advance	the	public knowledge	base	for	such	operations. Gerald	Thielemann is	committed	to	promoting the	UAS	research	efforts	of	policymakers	including	the	FAA,	NASA,	DOD	and	DARPA by	sharing data	from	its	commercial	UAS	operations	and	serving	as a	resource	for future	UAS	research operations.	Thus,	the	FAA	has	good	cause	to	grant	this	Petition. Conclusion As	pointed	out	in	this	application,	all	the	SUAs	which I would	use,	under authorization	by	the	US	DOT

- FAA,	are	small,	light

-weight	devices	operated	withinthe	line	of sight	of	the	Pilot

- in

- Command	(PIC),	less	than	400	feet	above	the	ground

and	outside	5	miles from	any	airport,	heliport,	seaplane	base,	spaceport,	or	other location	with	aviation	activities, unless	the	air	traffic	control	authoritie s	(ATC)	have been	notified	and	have	authorized	each	flight within	a	radius	of	this	distance. All	our	SUAs	have	proven	capability	for	controlled	flight.	They	are	devices	offered for	general sale	on	the	market	around	the	world	and	have	often	been	used	as	Mo del Aircraft	in	the	USA. We	a	re	certain	that	the	studies	conducted	until	now	by	the	FAA, about	Section	332,	Public	Law 112

- 95,	2014,	have	already	provided	you	with	the assurances	on	the	airworthiness	of	SUAs such	as	ours. For	the	foregoing	reasons,	the exemptions	requested	herein	should	be	granted	and Gerald	Thielemann should	be	permitted	to	conduct	small	UAS	operations	in accordance with	its	manuals	and	all	other	operating	parameters	deemed	necessary and	appropriate	by	the FAA.	The	submission	of	this	ap plication	and	its	contents	is the	best	demonstration	that	indeed	it is	possible	to	pursue	the	authorization process so	that	some	SUAs	may	be	used	for	legitimate commercial activities	and	under reasonably	safe	conditions.