I. Name and Information

David E. Anderson

4540 Bowl Street New Port Richey, FL 34652
(727) 271

- 5588 Anderson7314@gmail.com

I, David E. Anderson, received my Ass ociates Degree in Architecture from Purdue University, Indianapolis, Indiana, and continued on to receive my Bachelor of Science in Construction Management in 1985. I am a Class A State Certified General Contractor with license #CGC055976 since August 1, 1996 and a Florida State Certified Home Inspector license #HI1596 since February 15, 2011, both licenses are active in the State of Florida and are afforded reciprocity

i n numerous other states. I also have an active membership in the Academy of Model Aero nautics dating back to 19 82, license # 83430. My interest in UAS’s also includes unmanned water vessels, and I, David E. Anderson, also have a Life #16565 S in the International Model Power Boat

Association which dates back to 1995.

I, David E. Anderson, received my Student Pilot Certificate with 38.9 hours Dual, and 16.2

hours Solo for a total of 55.1 hours. This i nclude s 1.0 hours of Instrument

, and 13.0 hours of Cr oss C ountry, along with over 10 hours of ground school training. I am f ully familiar with the FAA rules and regulations governing airspace “no

- fly zones” and I agree to fully comply with all FAA regulations in a manner consistent with those followed by a licensed pilot in the operation of my

UAS.

I, David E. Anderson, currently own a DJI Phantom Aircraft with a 1080 HP camera and

intend to add other UAS’s to my inventory for the intent of aerial GPS Global Mapping, Commercial and Residential Inspections, Insurance Inspections for damage claims as well as documenting ex isting conditions for Insurance Companies

, Construction Management and

i nspections of new and renovation projects including the interior of buildings , and potential government assistance as needed. A s the owner/principal of the following com panies incorpor ated

within the S tate of Florida, this exemption will be used for the above purposes by myself and/or one of my following business entities for the exclusive use of my self, business, or clients

.

1. Anderson Inspections, Inc. , 5/31/2005;

2. dba: Anderson Cons truction Group; 1/17/2007;

3. dba: Anderson Hurricane Protection: 3/27/2009;

4. dba: Anderson: 7/23/10.

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which

David E. Anderson Requests Exemption 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).

III. The Extent of R elief David E. Anderson S eeks and the Reason He Seeks Such Relief:

I, David E. Anderson , submit this application in accordance with the Reform Act, 112 P.L. 95 § § 331

- 334, seeking relief from currently applicable FARs operating to prevent me, David E.

Anderson , contemplated commercial cinematic, academic and other flight operations within thePage 2 of 6

national airspace system . The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s best interest to

do so.

My, David E. Anderson 's, ultralight weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultralight weight UAS is expressly contemplated by the Reform Act

.

The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: weight, size, speed and overall capabilities of the UAS's ; w hether the UAS will be operated near airports or heavily populated
areas; and, w hether the UAS will be operated by line of sight. 112 P.L. 95 § 3 33 (a). Each of these items reflect in favor of an exemption for me, David E. Anderson

.

My UAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology , and weighs under three ( 3 ) pounds (below the maximum 55 pound limit); including camera with gimbal.

I, David E. Anderson , consider safety as foremost with each flight. My small, unmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. Built in safety systems include a GPS mode that allows my UAS to hover in place when radio

controls are released. With three modes to choose from, I utilize the GPS Mode for aerial videography/photography. This is the safest, most relia ble and stable mode to prevent accident s

. If pilot communication is lost

, UAS are designed to slowly descend to the original point of takeoff. I do not operate my UAS near airports, h ospitals , p olice heliports, and , with the exception of my clients being present, will not operate near areas where the general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft and am prepared to lower/ land/abort immediately to t he nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location.

My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight, as the remote control pilot, or with my licensed PIC. The equipment runs on battery

power and an average flight generally takes between three (3) to twelve (12) minutes, with an

altitude under two hundred (200) feet. I, David E. Anderson , utilize a fresh fully charged battery with each flight as a safety precaution; the average flight time limit for each battery is twe nty (2 0 )

to twenty

- five (2 5 ) minutes as tested. I do not operate my UAS at or below manufacture r’s recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at han d with each exercise to insure replacement for sufficient safe level of operation. I have clocked numerous practice flights

in remote areas to hone my skills with the characteristics of this specific UAS's performance

under different temperature s and weath er conditions. In addition to my concern and respect for the use of this machine, I have a financial investment at stake and do not wish to take any unnecessary risks to jeopardize the safe return of my investment.

I, David E. Anderson , am extremely cautious when operating of my UAS/ultralight weight

unmanned aircraft and will not “create a hazard to users of the national airspace system or thePage 3 of 6

public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s co ntemplated safety zone when it implemented the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. My, David E. Anderson ’s UAS has a demonstrable safety record and does not pose any threat to the general public or national security.

IV. How David E. Anderson ’s Request Will Benefit the Public As A Whole:

Th e i nh ere n t ab ili t y o f t h e U A i s t o c ap t u r e i m a ger y fr o m a l o w a l t i t ud e i n c l ud i n g
ob li qu e pho t o s an d v i de o fr o m s e v e ra l a n g l e s i s fa r m o r e e ff e ct i v e t h a n gr ound b as e d i m ag e r y for display i ng the character i st i cs of bu il d i ngs, sites and propert i es or areas where inspections

are needed

. The app li cant i n the past has required a ladder for th i s purpose, wh i ch creates a

hazard and potent i a l for serious injury. The property owner or construction manager would

benefit from an aerial “real

- time” inspection of the area so that he/she may assess the situation and proceed in their best interest s

. The reduced cost and h i gher qual i ty data from the U A w ill

be b e n ef i c i a l t o t h e pub li c i n app li c a t i on s whe r e acc e s s i s li m i t e d a n d reduce if not eliminate any potential for injury by the property o wner to inspect the situation. Construction projects will proceed in a timely fashion with the use of this equipment and it will assist property buyers in evaluating the condition of their property without risking serious injury or death for an up

- close

vi ew.

Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. The same is also true for construction sites, land surveying, and all aspects of property inspections and evaluations in both residential and commercial arenas.

My, David E. Anderson ’s, UAS does not pose any threat since size and lack of

combustible fuel alleviates any potential harm 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 system, hence the passing of the Refor m Act. My ultralight weight UAS is battery powered and

creates no emissions that can harm the environment.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ul tralight weight UAS's. Permitting me,

David E. Anderson , to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furth ers the economic impact for companies looking to relocate or build in the area as well as individuals looking to relocate which is a stimulus to the economy of the community.

V. Reasons Why David E. Anderson ’s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My, David E. Anderson ’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, David E. Anderson , to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for
Realtors, construction sites, land surveying, location historical documentation, andPage 4 of 6

infrastructure i nspections that can be embraced by the NAR, AAR, and TAR for development in cooperation with the FAA. In addition I, David E. Anderson , submit the following representations of enhancements to current aerial videography and photography for real estate,

cons truction sites, land surveying, location historical documentation, infrastructure inspections, athletic field marketing and maintenance:

My UAS, a Phantom 2 manufa ctured by DJI weighs less than three (3) pounds complete with a small ultralight weight high quality 1080 HD camera ;

I , David E. Anderson

, only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only operates for 12

- 2 5 minutes per flight; I land my UAS prior to manufacturer recommended minimum level of battery power; I pilot my UAS through remote control only by line of sight; My UAS has a GPS flight safety feature whereby it hovers and then slowly lands if

communicati on with the remote control pilot is lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from

power lines, elevated lights, airports and actively populated areas; I conduct extensive pre

- flight inspections and protocol, during which safety carries primary importance;

I obtain all necessary permissions prior to operation; and, I have procedures in place t o abort flights in the event of safety concerns or potential danger.

My, David E. Anderson ’s, safety protocols provide a level of safety equal to or exceeding existing rules. Further, my hours of flight instruction will benefit me, my clients, and the community as I will be held to a higher standard of care based on my knowledge of FAA rules and regulations that exceed most UAS operators

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and operational area of m y, David E. Anderson 's, UAS permits exemption from Part 21

because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximit y to areas

such as airports and dense populations. My, David E. Anderson , current and projected UAS's

meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate.

As no such certificat e will be applicable in the form contemplated by the FARs, this RegulationPage 5 of 6

is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 873 8, 9299, 9299A, 9565, 9565B, 10167, 10167A,
10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me,

David E. Anderson

.

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with

dimensions smaller that minimal lettering requiremen t. Regardless, I will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by

14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FA A has previously issued exemptions to this regulation through Exemptions
Nos. 8738, 10167, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I, David E. Anderson , can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control pi loting skills. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R.
§ 61, et seq. Thus, allowing me, David E. Anderson , to operate my UAS meet and exceed current safety l evels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. I, David E. Anderson

, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below t hose in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be

achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b):Page 6 of 6

Maintenance Inspections.

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, hav e discrepancies repaired as prescribed in part 43 of this chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, David E. Anderson 's, UAS. However, as a safety precaution I careful ly and thoroughly inspect my UAS before and after each flight.

In summary, David E. Anderson seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R.§ 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, David E. Anderson ’s , small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, grounds and building maintenance, infrastructure inspections, real estate operations, and to develop economic platforms for real estate to enhance the experience of those seeking to construct and/or purchase

residential or commercial structures

.

My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more

maneuvera ble than conventional video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airfields. There are no personnel on board my, David E.

Anderson ’s , UAS and therefore the likelihood of death

, serious bodily injury , or any injury is significantly diminished. My, David E. Anderson 's, operation of my UAS, weighing less than three (3) pounds and traveling at lower speeds within lim ited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, David E. Anderson

, respectfully request that the FAA grant my exemption request

. This request follows many others using similar systems and process th at have been granted previously. My request

for the FAA to issue a n exemption would not set a precedent and I respectfully request this request be granted.

Respectfully Submitted,

Da vid E. Anderson

/lmf