## UNITED STATES OF AMERICA
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION

Exemption Request Section 333 of the FAA Reform Act

Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Regulatory Docket Number ______________

Petitioner: October 7, 2015

Michael J. Pettit 200 E. Racquet Club Rd. Unit 6 Palm Springs, Ca. 92262
760-327-8625 petitemichael@hotmail.com

DEAR SIR, MADAM;

This petition is being submitted on my own behalf in accordance with the FAA’s Guidelines for Submitting a Petition for Exemption un der section 333 of the FAAModernization and Reform Act of 2012. I Michael J. Pettit, referred to hereafter as

the petitioner / operator, request exemption from th e following sections of the Federal Aviation Regulations for the purpose of aer ial photography, videography, advertising, real estate inspections and promotions, golf course construction, maintenance, and promotional ads, surveying and mappin g operations, crop surveying, construction site development, and inspe ctions of towers and other structures.
14 C.F.R. 45.23 (b)
14 C.F.R. Part 21 (h)
14 C.F.R. 61.113 (a) (b), 91.7 (a), 91.9 (b) (2), 9 1.103 (b), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), 91.417 (a) (b).

The petitioner / Operator holds a private pilot lic ense, single engine land with an instrument rating, and a valid California Drivers L icense. The Petitioner / Operator also has 50+ hrs. flying and operating small RC air craft. The aircraft to be used during these commercial operations will be the DJI I nspire 1.

UAS
Please see the following attachments and or links fo r the DJI Inspire 1.
Specifications: http://www.dji.com/product/inspire-1/spec

Maintenance Manual: http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Mai ntenance_ManualV1.0_en.pdf

User Manual: http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Use r_Manual_v1.0_en.pdf
Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unman ned air systems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.
The DJI Inspire 1 utilizes an internal inertial meas uring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is control led primarily through an FCCcertified radio control (RC) unit. Real time video and telemetry information is

transmitted back to ground control station allowing the operator and/or PIC to monitor battery level GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Batt ery life limits flight times to approximately 25 minutes. The onboard flight co ntroller will warn the pilot via telemetry and external lighting cues before reachin g a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated the fl ights will usually last less than 10 minutes.

SAFTEY FEATURES
The UAS has several safety features which will minimi ze the potential for fly-aways and maximize the safe and efficient use of the aircr aft in the NAS. The DJI Inspire controller provides Intelligent Orientation control (Home Lock and Course Lock Features.) The Hone Lock Feature allows for a safe return should the operator get disoriented as to the direction the aircraft is movi ng. Once activated on the remote control, the operator can simply pull back on the ri ght control stick and Inspire will return to the remote control regardless of the airc raft’s location from the remote control.
The “lost – link” feature will allow the Inspire to climb or descend to a pre-assigned altitude and return to the point of departure and l and itself.

AIRCRAFT OPERATIONS AND EQUIVALENT LEVEL OF SAFTEY

- Operations authorized by this grant of exemption wi ll be limited to the aircraft described in the operating documents, rotorcraft UA Ss weighing less than 55 pounds maximum gross weight: DJI Inspire 1

- The UAs will not be flown at an indicated airspeed exceeding 40 knots.

- The UAS will be operated at an altitude of no more t han 400 feet above ground level (AGL), as indicated by the procedures specifi ed in the operating documents unless a special request is made and appr oved by ATC.

- Visual line-of-sight (VLOS) only; the unmanned airc raft will remain within VLOS of the operator or visual observer, without an y other visual aids. (FPV)

- All operations will be conducted during official da ylight hours, local time.

- A COA will be obtained through the local ATC if ope rations will be conducted outside of class G airspace. Or operation that exce ed the blanket COA.- The Petitioner will not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may not operate withi n 5 nautical miles of the geographic center of non-towered airport as den oted on a current FAApublished aeronautical chart unless a letter of agr eement with that airport’s management is obtained, and the operation is conduct ed in accordance with a NOTAM as required by the operator’s COA. The lette r of agreement with the airport management must be made available to the Admin istrator upon request.

- All operating documents, including the “grant of exe mption” will be available upon request to the Administration and or Local Auth orities.

- A pre-flight check will be done before each flight / or operation, in strict accordance with the DJI Inspire 1 Manual’s pre-flig ht check list. Any maintenance or repairs will be documented in the airc rafts Maintenance Log.

- The operator will be trained in all flight operatio n and safety procedures as detailed in this document and the DJI Manual, with all the updated information related to the DJI Inspire 1.
Any accident which results in injury or property da mage will be reported to the FAA within 10 days.

- The aircraft will be identified by an N-number in ac cordance with 14 C.F.R. Part 47.

- Radio frequency for all operations will comply with the FCC.

- The operator is a licensed private pilot with exten sive aeronautical knowledge. The operator will always yield to manne d aircraft, and never operate the aircraft from a moving vehicle.

- Written and / or verbal permission and permits will b e obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

-

SPECIFIC EXEMPTIONS AND EXTENT OF RELIEF SOUGHT:
14 C.F.R. 45.23 (b) 

### (Aircraft Identification Number and the word Experi mental)

• The DJI Inspire 1, is an unmanned aircraft with no cabin, cockpit, or pilot station. If required the word Restricted or Experi mental can be placed on the aircraft, in a size appropriate for the space allow ed. The same can be accomplished with the “N” number if there is not an exemption from the aircraft registration process.14 C.F.R. PART 21 (h) 

### (Airworthiness Certificate)

• Given the size and limited operating area associate d with the aircraft to be utilized by the Petitioner , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. 44701 (f) and Section 333 of the Reform Act both authorize the FAA to exempt a ircraft from the requirement for an airworthiness certificate, upon c onsideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an anal ysis of these criteria demonstrates that the UAS operated without an airwor thiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft ope ration with an airworthiness certificate without the restriction and conditions proposed.
14 C.F.R. 61.113 (a) (b) 

### (Private Pilot Privileges and Limitations)

• The petitioner requests relief in order to facilita te the utilization of pilots, who hold a Private Pilot certificate and a valid driver ’s license, to conduct the proposed flight operation for compensation or hire. Any pilots operation under this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted e xemptions.
91.7 (a) 

### (Civil Aircraft Airworthiness)

• To the extent that the petitioner’s UAS is not elig ible for an airworthiness certificate under 14 C.F.R. Part 21, therefore it c annot be airworthy in the context of the regulation.
91.9 (b) (2) 

### ( Civil Aircraft Flight Manual, Marking, and Placar d Requirements)

• The petitioner request an exemption to this requirem ent since the aircraft is not only too small to carry documentation, the docume ntation would not be available to the crew during flight operation. To obtain an equivalent level of safety and meet the intent of 91.9, a current, appr oved UAS Flight Manual will be available to the crew at the ground station anyt ime the aircraft is in, or preparing for flight.
91.103 (b) 

### (Pre-flight Action)

• Prior to each flight the PIC will conduct a pre-fli ght check and inspect the UAS to ensure that it is in a condition for safe fligh t and the PIC will also follow all operation and flight manual training and procedures as prescribed in the DJIInspire 1’s User’s Manual and Pre-flight checklist. If an inspection reveals a condition that affects the safe operation of the UA S, the aircraft is prohibited from operation until the necessary repairs have been performed, and the UAS is found to be in a condition suitable for safe fli ght.
91.119 (c) 

### (Minimum Safe Altitude)

• As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may re quire that the UAS be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitio ner requests modification, waiver or exemption and clarification concerning th e terms “congested areas” and “densely populated”. The petitioner (Michael J . Pettit) requests a waiver for this condition to allow reasonable and responsi ble operations with safety as my main concern in areas of subdivisions and neig hborhoods if required. Since the typical mission of the UAS would be photog raphy, surveying of persons, vessels, vehicles or structures, it would be necessary to operated closer than 500 feet to the items listed. Operation s will only be flown over property or persons where permission has been obtain ed and careful preplanning has been performed



### . 91.121 

### (Altimeter Settings)

• As discussed in Exemption 11138 (DOUGLAS TRUDEAU) t his is inapplicable since the UAS does not have an altimeter and instea d utilizes electronic GPS with a barometric sensor for altitude information. An equivalent level of safety will be achieved by the operator, pursuant t o the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.
91.151 (a) 

### (Fuel Requirements for Flight in VFR Conditions)

• The UAS provides battery power remaining in percent to the PIC. The UAS batteries provide approximately 25 minutes of powere d flight. Information provided in operating documents, discuss procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when batt ery power remaining reaches a specified level. Given the limitations on proposed operations, and the location of those proposed operations, the FAA found that a reduced minimum power reserve for flight in daytime VFR condi tions was reasonable.
91.405 (a), 91.407 (a) (1), 91.409 (a) (2), 91. 417 (a) (b) 

### (Maintenance Required)• As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operation documents. The FAA f ound that adherence to the petitioner’s operation documents and the conditi ons and limitations specified, describing requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safet y would not be adversely affected. All required maintenance will be document ed and maintained utilizing the maintenance log.

PUBLIC INTEREST
Instead of using manned aircraft, the UAS will great ly benefit the public by drastically reducing the levels of air and noise po llution generated during traditional aerial flight operations. Without aircrew members and highly flammable fuel onboard, there will be less potential for a catastr ophic event. Crop surveying application could lead to decreased use of pesticid es and fertilizers and conservation of water as well as increased crop yie lds and decreased costs. Aerial surveying and inspections can increase work site ef ficiency, improve volumetric estimation and reduce risks. The UAS will minimize ec ological damage and promote economic growth by providing information to businesse s and individuals in their perspective industries. In the past, it has been c ost prohibitive for most small businesses to obtain this type of service, due to t he low cost operations of the UAS, these operations will open up a whole new level of commerce, which will add to economic growth for all.

I, Michael J. Pettit respectfully request exemption under Section 333 to operate safe, low-risk commercial UAS operations for the act ivities stated above. I will respect the space of citizens and property and ende avor to keep our skies safe.

Thank You for Your Consideration.
Respectfully Yours,

Michael J. Pettit
200 E. Racquet Club Rd. Unit 6
Palm Springs, Ca. 92262

760-327-8625
petitemichael@hotmail.com