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**Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations** 

**Dear Sir or Madam:**

**Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11,**  **Chris Dunn [unmanned aerial systems], seeks**  **an exemption from the Federal Aviation Regulations ("FARs") listed below to allow commercial operation of its**  **UAS' so long as such operations are conducted within**
**and under th e conditions outlined herein or as may be established by the FAA as**  **required by Section 333.**

**The requested exemption would permit commercial operation of Chris Dunn**  **[unmanned aerial systems, a multi rotor aircraft, weighing less than 55 lbs. including car** **go. The applications for this UAS device would consist of still photographs and/or video taken by an onboard camera and associated data**  **processing functions and used for aerial videography and photography for weddings special**  **events, real estate, filmmaki ng, a**  **erial inspections on construction**
**sites of difficult to reach equipment or structures** **, cell towers and small cells**  **. The p rivate use including**  **real estate, architect ure, land surveying** **, sports promotions**
**, landscaping and other related**  **professional acti vities.** 

**Use of the UAS for these purposes reduces the need to operate conventional aircraft or other**  **equipment for the same purpose and provides very high quality imagery at a fraction of the cost of**  **surveys and inspections using conventional means. Like wise, inspections of**  **structures can be safely performed without endangering the inspector or inhibiting**  **local industrial or public operations with ladders, lifts or other equipment. These**  **savings result in enhanced safety. efficiency and productivity**
**for t he affected**  **activities, as well as environmental benefits and potential savings in both cost and hazards to the public.** 

**The name and address of the applicant is:**

**Michael Dunn**
**102 Alanwood Ct. Warner Robins, Ga 31093** 
**478**

**- 960** 

**- 4669**  **Chris@DunnOnsite.com Small UAS Certificate of Registration** 
**CERTIFICATE HOLDER: Michael Dunn** 
**UAS CERTIFICATE NUMBER: FA3RCY9KCL 3DR Solo # S111A5604278** 
**DJI Phantom 2 Vision + Section 333 Exemptions** 
**FAA**

**- 2007** 

**- 0001** 

**- 0001** **Page 2**

**Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 417 (a) & (b)**  **14 C.F.R. 45.23(b) 14 C.F.R. 409 (a) (2) 14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 407 (a) (1)**  **14 C.F.R. 91.7 (a) 14 C.F.R. 91.405 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.203 (a) & (b)** 
**14 C.F.R. 91.103 14 C.F.R. 91.151 (a)** 
**14 C.F.R. 91.109 14 C.F.R. 91.121**
**14 C.F.R. 91.119**

**Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may**  **operate safely in the national airspace system (NAS) before completion of the**  **rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of sUAS' do not**  **create a hazard to users of the NAS or the public or pose a threat to national security**  **in light of the following: • The sUAS' size, weight, speed, and operational capability;**  **• Operation of the sUAS in close proximity to airports and populated areas; and • Operation of the sUAS within visual line of sight of the operator.** 

**R eform Act 333 (a) If the Secretary determines that such vehicles "may operate**  **safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system."** 
**The Federal Aviation Act expressly grants the FAA the authority to issue**  **exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under 40101 of the Act, that includes sUAS', from the**  **requirement that all civil aircraft must h ave a current airworthiness certificate.**  **Wright Bros. understands this provision to place the duty on the Administrator to not only process applications for exemption under section 333, but for the**  **Administrator to craft conditions for the safe operation of the sUAS, if it should be determined that the condition set forth herein do not fulfill the statutory**  **requirements for approval.**

**U.S. Department of Transportation Docket Operations**  **West Bldg Gro und Floor, Room w12** 

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**The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702** 

**- 44716**  **of this title if the Administrator finds the exemption in the public interest. 49 U.S. C.**  **44701(f) See also 49 USC 44711(a); 49 USC 44704; 14 CFR 91.203 (a) (1). Wright Bros. will use a multiblade rotorcraft built by myself (Ref: A&P Certificate**  **Number 3729542) we ighing less than 55 lbs. including payload. It operates under**  **normal conditions at a speed of no more than 30 knots and has the capability to hover, and move in the vertical and horizontal plane simultaneously. It will operate**  **only in line of sight (LOS) o f the pilot and will operate only within the project area.**  **Such operations will insure that the sUAS will not create a hazard to users of the national airspace system or the public.** 
**Given the small size of the sUAS involved and the restricted environment w ithiri**  **which it will operate**

, **Dunn Aerial Photography . falls squarely within that zone of SAFETY (an**  **equivalent level of SAFETK) in which Congress envisioned the FAA must, by exemption, allow commercial operations of sUAS to commence immediately. Also** 
**due to the size of the sUAS and the restricted areas in which the relevant sUAS will**  **operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the** 
**Federal A viation Act, as amended; the strong equivalent level of SAFETY**  **surrounding the proposed operations, and the significant public benefit, including enhanced SAFETY. reduction in environmental impacts, including reduced**  **emissions associated with allowing sUAS for event and inspection operations the**  **grant of the requested exemptions is in the public interest. Accordingly, Wright Bros. respectfully requests that the FAA grant the requested exemption without**  **delay. Aircraft and equivalent Level of SAFETY** 

**Dunn Aerial Photography**  **. proposes the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These**  **limitations provide for at least an equivalent or even higher level of SAFETY to operations under the current regulatory structure because the proposed operations**  **represent a SAFETY enhancement to the already safe photography and surveying operations conducted with conventional aircraft.** 

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**These limitati ons and conditions to which Chris Dunn**  **. agree to be bound when conducting commercial operations under an FAA issued exemption include:**  **1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/or observer.**  **3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve shoul**  **d that occur prior to the 20 minute limit.**  **4. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Minimum crew for each operation will consist of the sUAS Pilot and a Visual** 
**Observer. 6. sUAS Pilot will be a skilled sUAS operator exper**  **ienced in the type of UAS**
**flown. 7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other**  **than the sUAS Pilot, who possess the necessary PIC qualifications, is also present that person can also be designated as PIC.** 
**8. The sUAS wil l only operate within a confined Project Area.**  **9. A briefing will be conducted in regard to the planned sUAS operations prior to aerial activities. All personnel who will be performing duties within the**  **boundaries of the SAFETY perimeter will be made aware of the sUAS**  **flight(s). 10. The operator will obtain the consent of all persons involved in the project**  **and ensure that only consenting persons will be allowed within 100 feet of the flight operation.**  **11. Pilot and observer will have been trained in operat ion of sUAS generally and**  **received up**

**- to** 

**- date information on the particular sUAS to be operated.**  **12. Observer and pilot will at all times be able to communicate by voice andjor**
**visuals. 13. Written and/or oral permission from the relevant property holders**  **will be**
**obtained. 14. All required permissions and permits to be obtained from territorial, state,**  **county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.** 
**15. If the sUAS loses communications or loses its GPS signal, the sUAS will have**  **capability to return to a pre**

**- determined location within the Security** 
**Perimeter and land. 16. The sUAS will have the capability to abort a flight in case of unpredicted**  **obstacles or emergencies**

**U.S. Department of Transportation Docket Operations**  **West Bldg Ground Floor, Room w12**

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**Description of Specific Regulations: 14 CFR Part 21, Subpart H: Airworthiness Cert**  **ificates 14 C.F.R. 91.203 (a)(1) Subpart H, entitled Airworthiness Certificates, establishes the procedural**  **requirements for the issuance of airworthiness certificates as required by FAR 91.203 (a) (1). Given the size and limited operating area associated**  **with the aircraft to be utilized by the Wright Bros., 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 (0) and Section 333**  **of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an**  **airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular SUAS.**  **Our small sUAS will be operated at low speed in a controlled environment at least five miles from an airport. An analysis of these criteria demonstrates that the SUAS**  **operated without an airworthiness certificate, in the restricted environment and**
**under the conditions proposed will be at least as safe. or safer. than a conventional**  **aircraft (fixed wing or helicopter) operating with an airworthiness certificate without the restrictions and conditions proposed.**  **The sUAS to be operated hereunder is less tha n**  **55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and**  **operates exclusively within a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled an**  **d monitored by the operator, pursuant to the Manual's requirements, and under the requirements and in**  **compliance with local public SAFETY requirements, to provide security for the area of operation as is currently done on active construction sites. The FAA**  **will have advance notice of all operations.**  **These SAFETY enhancements, which already apply to civil aircraft operated in connection with construction sites, provide a greater degree of SAFETY to the public**  **and property owners than conventional operations conducted with airworthiness**  **certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security**  **posed by the sUAS, due to its size, speed of operation, locat ion of operation, lack of**  **explosive materials or flammable liquid fuels, and ability to carry an external load no greater than two lbs.** 

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**14 C.F.R. 45.23(b): Marking of the Aircraft**  **This regulation requires certain experimental, provisionally certificated aircraft, or light sport category aircraft to be marked with letters between 2 inches and 6 inches**  **high "limited," "restricted," "light**

**- sport," "experimental," or "provisional," near each**  **entrance to a cabin, cockpit, or pilot station. Even though the sUAS will have no airworthiness certificate, an exemption may be** 
**needed as the sUAS will have no entran ce to the cabin, cockpit or pilot station on**  **which the word "experimental" can be placed. Given the size of the sUAS, two**

**- inch**  **lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with 45.29 (t). The equivalent**  **level of SAFETY will be provided by having the sUAS marked on its fuselage as required by 45.29 (t) where the pilot,**  **observer and others working with the sUAS will see the identification of the sUAS as "Experimental." The FAA has issued the following exem**  **ptions to this regulation: Exemptions Nos. 107, 8738, 10167 and 10167 A.**  **14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in**
**Command Sections 61.113 (a) & (b) limit private pilots to non** 

**- commercial operations. Unlike** 
**a conventional aircraft that carries the pilot and passengers, the sUAS is remotely**  **controlled with no living thing or cargo on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance.**  **The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when**  **drafted, that allowing operations of the sUAS as requested with a pilot who is an experienced sU**  **AS operator exceeds the present level of SAFETY achieved by 14 C.F.R. 61.113 (a) & (b).**  **14 C.F.R. 91.7 (a): Civil aircraft airworthiness The regulation requires that no person may operate a civil aircraft unless it is in**  **airworthy condition. As there will be no airworthiness certificate issued for the**  **aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements** 
**contained in the Manual for maintenance and use of SAFETY checklists performed**  **by myself prior to each flight, an equivalent level of SAFETY will be provided.** 

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**14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements**  **The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on**  **board, but because there is no room or capacity to carry such an item on the aircraft. The**  **equivalent level of SAFETY will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to**  **it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A 10602, 32827 and** 
**10700. 14 C.F.R. 91.103: Preflight Action**  **This regulation requires each pilot in command take cert ain actions before flight to**  **ensure the SAFETY of flight. An exemption is needed from this requirement, as the pilot will take separate preflight actions, including checking for weather conditions,**  **checking flight battery requirements, checking takeoff and landing distances, and all**  **other actions in the Preflight Checklist, in the sUAS Manual. These actions will provide an equivalent level of SAFETY.**  **14 C.F.R. 91.109: Flight Instruction Section 91.103 provides that no person may operate a civil aircraft (ex** **cept a manned free balloon) that is being used for flight instruction unless that aircraft has**  **fully functioning dual controls. By design, sUAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through**  **the use of**
**a control box that communicates with the aircraft via radio communications. The FAA has previously approved exemptions for aircraft without fully functional dual**  **controls. See Exemption Nos. 5778K & 9862A. The equivalent level of SAFETY provide**  **d by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS via radio signals from the controller, and by**  **the size and speed of the aircraft.**

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**14 C.F.R. 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section**  **91.119 (d) allows helicopters to be operated at less than the minimums prescribed,**  **provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multirotor craft that**  **flies similarly to a helicopter, with vertical take off and vertical landing, which will typically operate at altitudes of 200 AGL an exemption may be needed to allow such**  **operations. The sUAS will never operate at an altitude higher than 400 AGL and will be in a restricted area, where buildings and people will not be exposed to operations**  **without their pre**

**- obtained consent. The equivalent level of SAFETY will be**  **achieved given the size, weight and speed of the sUAS as well as the location where**
**it is operated. No flight will be taken without the permission of the property owner**  **and any onsite personnel all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far** 
**more tha n the maximum 55 lbs. proposed herein and carrying flammable fuel, any**  **risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operation at or below 500 AGL in the**  **industry. In additio n, the low** 

**- altitude operations of the sUAS will ensure separation**  **between these small sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.**  **14 C.F.R. 91.121: Altimeter Settings This regulation requires each perso**  **n operating an aircraft to maintain cruising altitude by reference to an altimeter that is set ... "to the elevation of the departure**  **airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter,**  **but instead a GPS altitude read out, an exemption may be needed. An equivalent level of SAFETY will be achieved by the**  **operator, pursuant to the sUAS Manual and SAFETY Checklist, confirming the**
**altitude of the launch site shown on the GPS altitude indicato r before flight.**  **14 C.F.R. 91.151 (a): Fuel requirements for flight in VFR conditions Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR**  **conditions. Our sUAS is limited to operations in sterile and controlled environments**
**and has a limited range and flight time which require an exemption from 14 CFR**  **91.151(a). ,, '**  **U.S. Department of Transportation Docket Operations**  **West Bldg Ground Floor, Room w12**

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**The battery powering the sUAS provides approximately 20 minutes of powered flight. This does not meet the 30 minute**  **s reserve requirement in 14 CFR 91.151.**  **Dunn Aerial Photography . believes that an exemption from 14 CFR 91.151(a) falls within the**  **scope of p rior exemptions. See Exemption 10673 (allowing Lockheed Martin**  **Corporation to operate without compliance with FAR 91.151 (a)). Operating the small sUAS, in a tightly controlled area where only people and property owners or**  **official representatives who have signed waivers will be allowed, with less that 30**  **minutes of reserve fuel, does not engender the type of risks that Section 91.252 (a) was intended to alleviate given the size and speed of the small sUAS. An equivalent**  **level of SAFETY can be achieved by limiting flight to 15 minutes, or enough battery**  **reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power (as determined by the onboard monitoring system and the pilot),**  **whichever happens first. This restriction would be more than adequate to return**  **· the sUAS to its planned landing zone from anywhere in its limited operation area. Similar exemptions have been granted to other operations, including Exemptions**  **2689F, 5745, 10673 and 10808. 14 C.F.R. 91.203 (a) & (b): Car**  **rying civil aircraft certification and registration The regulation provides in part:**  **(a) Except as provided in 91.715, no person may operate a civil aircraft unless it has within it the following:**  **(1) An appropriate and current airworthiness certificate**

**... (b) No person may operate a civil aircraft unless the airworthiness certificate**  **Required by paragraph (a) of this section or a special flight authorization issued under 91.715 is displayed at the cabin or cockpit entrance so that it is**  **legible to passe ngers or crew.**  **The sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. Therefore there is no ability or place to carry certification and**  **registration documents or to display them on the sUAS. An equivalent level of SAFETY**  **will be achieved by keeping these documents at the ground flight control point where the pilot flying the sUAS will have immediate**  **access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A**  **representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797 A, 9816A** 
**and 10700.**

**U.S. Department of Transportation Docket Operations**  **West Bldg Ground Floor, Room w12**

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**14 C.F.R 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b); Maintenance Inspections**  **These regulations require that an aircraft operator or owner "Shall have that aircraft inspected as prescribed in subpart E of this part and shall between**  **required inspections, except as provided in paragraph (c) of this section, have discrepancies**  **repaired as prescribed in part 43 of this chapter . ," and others shall inspect or maintain the aircraft in compliance with Part 43. Given these sections and Par** **t 43 apply only to aircraft with an airworthiness certificate these sections will not apply** 

**to Dunn Aerial Photography**  **Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of SAFETY will**  **be achieved because these small sUAS' are very limited in size and will carry a small**  **payload and operate only in restricted areas for limited periods. If mechanical issues arise the sUAS can land immediately and will be in operation no higher than**  **400 feet AGL. The operator will insure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance**  **performed, (Ref: A&P Certificate Number 3729542). Moreover, the operator is the**
**person most familiar with the aircraft and best suited to maintain the aircraft in an**  **airworthy condition to provide the equivalent level of SAFETY.**

************* **Pursuant to 14 C.F.R. Part 11, [rule making] the following summary is provided for publication in the Federa**  **l Register, should it be determined that publication is**
**needed: Dunn Aerial Photography seeks an exemption from the following rules: 14 C.F.R. 21, subpart H;**  **[airworthiness certificates] 14 C.F.R. 45.23 (b); 14 C.F.R. 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2**  **); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a)(1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small**  **unmanned vehicle (55 lbs or less) in construction, inspection and events. Approval of exemptions allowin**  **g commercial operations of sUAS in the construction, surveying, special event or inspection industry enhances SAFETY**  **while reducing risk. Manned aircraft monitoring and surveying creates a greater risk because the craft are much larger, have combustible**  **fuel and carry an onboard pilot. In contrast, a sUAS will carry no passengers, crew or combustible fuel and;**  **therefore, will not expose them to the risks associated with manned aircraft flights.**

**U.S. Department of Transportation Docket Operations** 
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**The operation of small sUAS, weighting less than 55 lbs, conducted in the strict conditions outlined above, will provide an equivalent level of SAFETY supporting** 

**t he grant of the exemptions requested herein, including exempting Wright Bros.**  **from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground and in a sterile** 
**environment and as a result, are far safer than conventional operations conducted**  **with helicopters operating in close proximity to the ground and people. Privacy**  **All flights will occur over private or controlled access property with the property owner's prior consent and**  **knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where**  **aerial photography will take place. Satisfaction of the criteria provided in Section**
**333 of the Reform Act of 2012**

**- size,**  **weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and**  **national security**

**--- provide more than adequate justification for the grant of the**  **requested exemptions allowing commercial oper ation of Wright Bros. sUAS' in**  **special event, construction and inspection industry pursuant to the sUAS Manual. Specific Ex** **amples of Potential sUAS use by :**  **Dunn Aerial Photography [Unmanned Aerial**  **Videography} is currently in the process of building**

**a custom commercial airframe using OPEN source electronics including Alt Hold and**  **GPS functions to deploy if/when permission is granted. Construction of a similar yet**
**more advanced model to be introduced at a later date. Use of this tool would allow**

**Dunn Aer ial Photography to:**  **• Inspect existing inaccessible or difficult to access structures such as wind turbine towers, sides of bridges, industrial rooftops, and smoke stacks. This**  **would save time and money and public inconveniences by negating the need**
**to mob ilize large lift equipment or close roads during bridge or public**  **building inspections. • Enhanced public awareness. Dunn Aerial Photography use of aerial videography and still**  **photography for special events and the real estate market will enable the**
**clien t and those in attendance to better understand the proper and safe use** 
**of the sUAS venue as proposed by the FAA.** 

**Sincerely: Michael C. Dunn Dunn Aerial Photography** 
**UAS CERTIFICATE NUMBER: FA3RCY9KCL**