Norman Card, photographer, Selbyville Delaware

- Section 333 ExemptionPetition
16Feb2016 ', .,

U.S. DepartmentofTransportation Docket ManagementSystem ,_i f • '. •, '
1200 NewJerseyAve, SE Washington, DC 20590 . '. >''\ (]:

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Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear SirorMadam, I, Norman Card, am writing pursuant to the FAA Modernization and Reform Act of2012 and the procedures contained within 14 C.F.R. 11, to request that I, Norman Card, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listed below so that I, Norman Card, may operate my small ultra light weight unmanned aircraft system ("UAS") commercially in airspace regulated by the FederalAviation Administration ("FAA").
As described herein I, Norman Card, am a Photographer within the State of Delaware ; experienced in flying hobby helicopters for recreational purposes. I have added a hobby grade quad-copter, Phantom 3 Professional UAS to my inventory equipped with a Soney Exmor camera with intent for aerial videography/cinematography to enhance academic community awareness for those individuals and companies unfamiliar with the geographical layout of the suburban Delaware area, and augment real estate listing videos; following exemption and approval by the FAA. Thereby enhancing their academic research experience for the area. I plan to add a second quad-copterto my inventory in the future with comparable safetycapabilities.

I have flown small RC electric helicopters for over six (6) years without incident. Committed to safety with each flight and held a fixed-wing student pilot license My, Norman Card's , exemption request would permit operation ofultra lightweight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace. Predetermined in areas away from general public, airports, heliports and vehicular traffic catastrophe for community videos, and within property boundaries for individual homeowner real estate listing videos/photos. Currently, similar lightweight, remote controlled UAS's are legallyoperated by unmonitored amateur hobbyistswith no safety plan or controls in place to prevent

. I, Norman Card, have personally instilled safety

NormanCard, PhotographerSelbyville Delaware

- Section 333 ExemptionPetition

1protocols and controls to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's specific to real estate video and photography usage as I, Norman**Card~** record flight data and other information gained through permitted flight operations to sharewith the FAA through any required FAA reportsto assistwith future protocol and safety regulation. Granting my, Norman Card, request comports with the Secretary ofTransportation's (FAA Administrator's} responsibilities and authority to not only integrate UAS's into the national airspace system, but to "

...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system" under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/photography purposes. Further I, Norman Card, will conduct my operations in compliancewith the protocols described herein or as otherwise established bytheFAA.
For the reasons stated below I, Norman Card, respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS's for academic communityawarenessto benefit/stimulate attractiontothe**Appendix~A-User** manual Appendix-B-Quickstartguide Appendix-C-SafetyGuidelines Appendix-0-Propguards Appendix-E-Smile radius Ocean City, Maryland Appendix-F-Fiightcheck list

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### DelaiNarearea and to enhance real estate listing videos for homeowners who cannot afford expensive manned aircraft for the same purpose. Both of which will promote local economic growth through increased employment and increased tax base. Both with public safety in mind by keeping heavier manned aircraft containing combustible fuel that that poses potential publichazard.

Norman Card, Photographer 37406 ShadyWay Selbyville, Delaware, 19975 Mobile: (443) 523-9762 Email Buzzman1946@gmail.com



### I. The Specific Sections ofTitle 14 ofthe Code of Federal Regulations From Which Norman Card Requests Exemptionare:

14CFR21; 14C.F.R.45.23(b); 14CFR61.113 (a) & (b); 14C.F.R. 91, etseq.; 14CFR407 (a) (1); 14CFR409 (a) (2); and, 14CFR417 (a)& (b).

NormanCard, PhotographerSelbyville Delaware-Section333 Exemption

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### II. The Extent of relief Norman Card seeks and the Reason He Seeks Such Relief:
I, Norman Card, submit this application in accordance with the Reform Act, 112 P.L. 95 

### §§ 331-334, seeking relief from any currently applicable FARs operating to prevent me, Norman Card, contemplated commercial cinematic, academic and other flight operations within the 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 interestto do so. I, Norman Card, ultra light weight UAS meetsthe definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. Iwould like to operate my ultra lightweight UAS priortothe time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information forformal regulation that can be administered uniformlyto all real estate related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include:The weight, size, speed and overall capabilities ofthe UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.l. 95 

### § 333 (a). Each ofthese items reflect in favor ofan exemption for me, Norman Card. My UAS utilizes four (4) counter-rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit); including camerawith gimbal.
I, Norman Card, considers 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. For safety, stability and fear offinancial loss I will not fly in winds exceeding 16 kph (10 mph). 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 Smart Mode5foraerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost UAS is designed slowly descend to point oftake off. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate nearareas where general public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. I am constantly on alertfor any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspectmanned aircraft may approach near my location. My UAS is capable of vertical and horizontal operations, and are flown onlywithin my line ofsight ofme, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last betweenthree 15-20 minuteswith an altitude under one hundred fifty (150) feet

5Smart Mode includes safecircleforoperation, position hold, self-leveling, altitudecommand, GPS, retum homefeature, and safety controlto return home or land inthe event ofcommunication interruption between RC transmitterand UAS. SeeAppendixA - OperatorManual.
Norman Card, PhotographerSelbyville Delaware

- Section 333 Exemption I, Norman Card, utilize afresh fully charged batterywith eachflight as a safety precaution; full

4flighttime limitforeach battery is nine 15to 20 minutesastested. Ido notoperate my UAS at orbelow manufacture recommend minimum charge levels foroperation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss ofcontrol orhazard

Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level ofoperation. Ido not believe in taking riskthat maycause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights forfuture commercial use to gain familiarization with the characteristics of this specific UAS's performance under differenttemperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All forthe sake ofsafety.
I, Norman Card, am extremely cautious when operating of my UAS/ultra light weight unmanned aircraft and will not "create a hazard to users ofthe national airspace system or the public." 112 P.L. 95 

### § 333 (b). Given the small size and weight of my UAS it falls well within Congress's contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. Norman Card's UAS, used in hobbyflight, has a demonstrable safety record and does notpose any threattothe general publicornationalsecurity.


### Ill. HowNorman Card's RequestWill Benefitthe Public

### As AWhole:
Aerial videography for geographical awareness and for Photography marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget companies and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies and high end Photography can afford to absorb such expense. Depriving non-luxury homeowners and lower budget. Manned aircraft pose athreat to the publicthrough potential catastrophic crash thatthe Selbyville community has experienced in the past with military aircraft crashes within the city of Selbyville. Each resulting in loss aircraft. Each with combustible fuel that exploded and burned on impact. Police helicopters have made emergency hard landings within city limits. My, Norman Card, UAS pose no such threat since size and lack of combustible fuel alleviates any potentialthreattothe public. Congress has already proclaimed that it is in the public's interestto integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting my, Norman Card's, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the Selbyville Delaware area. My ultra lightweight UAS is battery powered and creates no emissions that can harm the environment. The consequence ofmy ultra light weight UAS crashing is far

5less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.

Norman Card, PhotographerSelbyville Delaware -Section333 Exemption

The public's interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra lightweight UAS's. Permitting me, Norman Card, to immediately fly within national air space furthers economic growth. Grantingmyexemption requestsubstantiallyfurthers the economic impactforthe Selbyville, Delaware communityforcompanies looking to relocate orbuild in the Selbyville area aswell as individuals looking to relocate for career advancement through academic and geographical awareness. Both ofwhich serve as a stimulus tothecommunity.


### IV.Reasons Why Norman Card Exemption Will Not Adversely Affect Safety Or How The ExemptionWill Providea Level ofSafetyAtLeast EqualTo Existing Rule: My, Norman Card, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Norman Card, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow meto contributeto the innovation and implementation ofnewand novel, as ofyet undiscovered safety protocolsfor Realtors that can be embraced by the Photographer for development in cooperation with the FAA. In addition I, Norman Card, submit thefollowing representations ofenhancements to currentaerialvideography and photographyfor realestate/photography.

MyUASweighs lessthan 5 pounds completewith a small ultra lightweight high qualityGoPro 3+ Blackcamera; Ieonly operate my UAS below 200 feet9 (well within the 400 foot permissible ceiling set bythe FAA Modernization and Reform Actof2012); flltY UAS onlyoperatefor 15-20 minutes perflight; I**~nd** myUAS priorto manufacturer recommended minimum level ofbatterypower; l.,ilotmy UASthrough remote control only by lineofsight; My UAS hasGPS aflightsafetyfeaturewhereby ithoversand then slowly lands if communicationwith the remote control pilot islost; Iectivelyanalyzeflightdata and othersources ofinformationto constantly update and enhancesafetyprotocols; 14>nlyoperate in reasonablysafeenvironmentthatare strictlycontrolled, areaway from power lines, elevated lights, airports and actively populatedareas; l.x>nductextensive pre-flight inspectionsand protocol, duringwhich safetycarries primaryimportance; Ielwaysobtains all necessary permissions priortooperation;and, 1

ehave procedures in place to abort flights in the event of safety breaches or potentialdanger.

6NormanCard, PhotographerSelbyvilleDelaware

- Section333 Exemption

Norman Card, safety protocols provide a level ofsafety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate. While the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra light weight UAS. F4rst, the potential loss oflife is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. Second, tAE3re is no fuel on board a UAS and thus the potential forfire or explosions is greatly diminished.**T~ird,** the small size and extreme maneuverability of my UAS allow me to remotely pilotawayfrom and avoid hazards quicklyand safely.**Lt~stly,** given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly, my UAS has been experimentally operated for familiarization/competency and will continueto operate atand above current safetylevels.
V. A SummaryThe FAAMay Publish inthe FederalRegister:



### A. 14C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manualsand TheLike.

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 enclosed operational area of my, Norman Card'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 aircraftfrom 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 proximity to areas such as airports and dense populations. My, Norman Card, current and projected UAS's meet orexceed each 

### ofthe elements.

14 C.F.R. 91.7(a) 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 C.F.R. 

### § 91.9 (b) (2) requires an aircraftflight 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 equiyalent level of safety will be achieved by maintaining a 7' 

# .

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. I, Norman Card, can achieve an equivalent level ofsafety as achieved bycurrent Regulations because my UAS does notcarry any pilots orpassengers. Further, while helpful, a pilot license will not ensure remote control piloting 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, Norman Card, to operate my UAS meet and exceed current safety levels in relation to 14C.F.R. §61.113 (a) & (b).

B. 14C.F.R. 91.119: Minimum SafeAltitudes.

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, Norman Card, will however operate my UAS in safe areas away from public and traffic, providing a level ofsafety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higherlevel ofsafetywill beachieved.
C. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### &(b): Maintenance Inspections.

NormanCard, PhotographerSelbyvilleDelaware

- Section333 Exemption

The above-cited Regulations require, amongst otherthings, 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) ofthis section, have discrepancies repaired as prescribed in part43ofthis chapter

...... These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, applyto my, Norman Caret, UAS. However, as asafety precaution I inspect my UAS before and after eachflight.


### A. Summary The FAA May Publish in the Federal Register: A. 14 C.F.R21 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 enclosed operational area of my UAS permits exemption from Part 21 because my, Norman Card's, UAS meets an equivalent level ofsafety pursuantto Section 333 ofthe 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 ofthe 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 proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. 

### § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UAS's, this Regulation is inapplicable. An8

## . 

# . equivalent level ofsafetywill be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level ofsafety will beachieved.

In summary, Norman Cardseeksan exemptionfrom thefollowing 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; 14C.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, Norman Card's, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness and, and to develop economic platforms for photography to enhance the experience of those seeking to relocate to the Selbyville, Delaware area. Currently, area awareness and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting my, Norman Card, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain potentially.

NormanCard, PhotographerSelbyville Delaware

- Section 333 Exemption

explosive fuel, is smaller, lighter and more maneuverable than conventional real estate 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. I, Norman Card, have been informally analyzing flight information and will compile safety protocols and the implementation ofa flight operations manual for real estate usage that"exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, Norman Card's, UAS and therefore the likelihood ofdeath orserious bodily injury is significantly diminished. My, Norman Card's, operation of my UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved undercurrent FARs. Accordingly I, Norman Card, respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and thegeneral publicatlarge. Respectfully submitted,

Norman Card

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