Joseph Meglio 1386 Autumn Trail Addison, IL. 60101 630-330-4820 Joemeglio@gmail.com

January 1, 2016

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140
1200 New Jersey Avenue, SE., Washington, DC 20590

Re: Petition of Joseph Meglio for an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act") and 14 C.F.R. Part 11, Joseph Meglio hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below, to allow commercial filming, cinematography and videography, and real estate listing imagery, using small unmanned aerial vehicles (i.e., "small unmanned aircraft" or “UAS”). Joseph Meglio seeks to operate a DJI Phantom 3 Professional in commercially regulated airspace regulated by the Federal Aviation Administration (“FAA”).
Joseph Meglio requests that the FA review this petition pursuant to it’s “summary grant” process as the FAA has already granted exemptions in all material respects to this potions to use the DJI Phantom 3 for aerial data collection. See FAA Grant of Exemptions Nos. 11062, 11109, 11112, 11213
Description of Petitioner:

Joseph Meglio intends to use the DJI Phantom 3 Professional a small UAS for basic aerial film and photography to be used for marketing and advertising creative work. Joseph Meglio’s flight operations will be conducted in a controlled area such as grasslands, prairies, lakes and woodlands, or neighborhoods away from spectators, and persons not involved with the creative work. In addition, the filming will be conducted during daylight, at low altitudes within the visual line of sight of the operator. Joseph Meglio will be the operator of the small UAS (“PIC”). Currently, similar lightweight small UAS’s are legally operated by unmonitored amateur hobbyists with no safety controls in place to prevent issue.

Description of Small UAS:
DJI Phantom 3 Professional is a quad rotor Small Unmanned Aircraft or UAS. The entire aerial device weighs in at 2.82192 pounds, considerably less than the 55 pound limit defining an Unmanned Aircraft. The Phantom 3 offers complete control with the use of a remote control a Pilot App via an iPhone,or iPad to a FPV other various levels of control. The device utilizes GPS and sensors to provide features such as “return to home” and a map overview of location. Joseph Meglio intends on only using this device within the visual sight line of theoperator (“VLOS”), and at altitudes less than 400 feet above ground level (“AGL). Before each flight the Phantom 3 will be inspected to ensure that is in a condition for safe operation. Planned flight will remain at least 500 feet from all non participating persons, vessels, vehicles or structures unless the owner/controller of any vessels vehicles or structures has granted permission for operating closer to those objects and Joseph Meglio has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. Anytime operation of the small UAS takes place on private property, permission will be obtained prior to operation.

Description of Exemption Request:

Joseph Meglio request exemption to use a UAS for aerial data collection (imagery {photography, video). The specific sections of Title 14 of the Code of Federal Regulations from which Joseph Meglio requests exemptions are:

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

Petition and Extent of Release (w/Reasons)

I request an exemption from

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)

The Extent Of Relief that Joseph Meglio seeks

1. Extent of Relief that Joseph Meglio seeks regarding Section 61.113 (a) and (b) Private Pilot Privileges and Limitations Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in Command holding a current Private Pilots Certificate to operate the Joseph Meglio Phantom 3. The flight would be complimented by a Visual Observer who, along with the pilot, will maintain Visual Line of Sight with the Phantom 3 at all times. All operations conducted will be incidental to Joseph Meglio's business. The Phantom 3 is not able to carry passengers.

2. Extent of Relief that Joseph Meglio seeks in regards to Section 91.7(a) Civil Aircraft Airworthiness Relief from Section 91.7(a) is requested to allow Joseph Meglio to determine airworthiness of the Phantom 3. As part of this determination the following will be adhered to: (a) Prior to the Phantom 3's flight the PIC will inspect the UA to ensure it is in a condition that will be conducive for a safe flight. The ground control station will be included in the above inspection.(b) Joseph Meglio will follow the DJI Phantom 3’s aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements.

(c) Joseph Meglio will comply with all DJI manufacturer Safety Bulletins.

3. Extent of Relief that Joseph Meglio seeks in regards to Section 91.119 Minimum Safe Altitudes General relief from 91.119 is requested to allow Joseph Meglio to operate the Phantom 3 at altitudes not to exceed 400’ AGL over property. Joseph Meglio will adhere to the following in order to maintain an acceptable level of safety associated with operations over private property:

(a) Joseph Meglio will display signs in the immediate vicinity of operations stating: “Aerial Photography In Progress. Use Caution.”

(b) Joseph Meglio will not allow the Phantom 3 to operate at a speed greater than 35 mph (16 m/s).

(c) Joseph Meglio will be fully trained on the Phantom 3 by adhering to the recommendations contained within the Phantom 3’s operating manual.

(d) Joseph Meglio will be familiar with and able to manually institute the Phantom 3’s Return to Home (RTH) feature. This feature aborts a flight operation and automatically returns the UAS to a predetermined GPS safe point.

(e) Joseph Meglio will not operate over private property without first finding a suitable alternate landing spot on the property.

(f) Joseph Meglio will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

(g) Joseph Meglio will utilize a two man flight team consisting of the Pilot in Command (PIC) and a Visual Observer (VO). This team will maintain visual line of sight with the Phantom 3 at all times and remain within hearing of one another.

(h) Joseph Meglio will not permit flight around vessels, vehicles and structures without permission from the owner.

5. Extent of Relief that Joseph Meglio seeks in regards to Section 91.121 Altimeter Settings. Relief from 91.121 is requested because the Phantom 3 utilizes electronic GPS with a barometric sensor. In order to maintain an equal level of safety that 91.121 requires, the PIC of the Joseph Meglio's UAS will abort the flight in the events that the UA loses communications with the GPS signal.

6. Extent of Relief that Joseph Meglio seeks in regards to Section 91.151(b) Fuel Requirements for Flight in VFR Conditions. Relief from 91.151(b) is requested to the extent that allows Joseph Meglio to operate the Phantom 3 up to a point (considering wind andforecast weather conditions) that there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.

7. Extent of Relief that Joseph Meglio seeks in regards to Sections 91.405(a), 91.407(a)(1), 91.409(a)(1), and (a)(2), 91.417(a) and (b) These are all associated a with Airworthiness certificate. Relief from 91.405(a), 91.407(a) (1), and (a)(2), And 91.417(a) and (b) is requested to the extent that allows Joseph Meglio to operate the Phantom 3 Quad-Copter as necessary. These sections are all related to airworthiness certificates of aircraft. There is not currently an airworthiness certificate for small UAS’s. Joseph Meglio would comply in full to any conditions and limitations that the Administrator would place in order to receive an approved Grant of Exemption.

Public Interest

Aerial videography for real estate marketing, and the outdoors industry has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, it’s expense has been cost- prohibitive. Granting this exemption to Joseph Meglio would allow me to provide this service at a much lower cost. My UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to manned aircraft. The operation of my UAS will minimize ecological damage and promote economic growth by providing information to companies, homeowners, and consume a business, relocate or build in the state of Illinois

.

Conclusion

As set forth herein, Joseph Meglio seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially within the FAA Commercially Regulated Airspace below 400’ AGL. The Administrator will be assisting small business by granting this petition. In accordance with the FAA Modernization and Reform Act of 2012, Joseph Meglio respectfully requests that the FAA Administrator grants this petition for exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS: 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121;91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)

Sincerely,

Joseph Meglio 1386 Autumn Trail Addison, IL. 60101 630-330-4820 Joemeglio@gmail.com