Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition Aer ial Services of Central Florida , LLC

James Partin

, Owner

4 209 Isle Vista Avenue

Belle Isle, FL 32812

407

- 592

- 6232



### aerialservicesofcfl@gmail.com

July 1 , 2015

U. S . D e p ar tm e nt of T ra n spo r t a tion

Do c k e t M a n a g e m e nt S y s t em

1200 N e w J er s e y Av e

, S E

W a shin g ton, DC 20590

R E : E x e mption R e qu e st S ec tion 333 of the F A A R ef o r m A c t of the Fe d e r a l Avi a tion

R e g ul a tions fr om 14 C

. F

. R . 45.23 ( b ) ; 14 C

. F

. R

. P ar t 21 subpart H ; 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. 2 03 (a ) & ( b ) ; 91.40 5 (a) ; 91

. 407 (a ) ( 1 ) ; 91.409 (a ) ( 2 ) ; 91.417 (a ) & ( b)

Dear Sir or Madam:

This petition is being submitted on our own behalf without legal council or consulting

services.

Aerial Services of Central Florida (“ASoCFL”) writing pursuant to Section 333 of the

F

AA Modernization and Re f orm Act of 2012 and the p r ocedu r es contained within 14

C

. F .R. Part 11, to r equest that ASoCFL

, an o wner and operator of small unmanned

ai r craft, be e x empted f r om the F ederal A viation Regulations (“ F ARs”) listed above so

that ASoCFL m a y legally operate small light w eight unmanned ai r craft system s

(“ U AS”) comme r cial l y in airspace r egulated b y the F ederal A viation Administration

(“ F AA”)

. ASoCFL humbly and respectfully requests exemption of the above noted

Federal Aviation Regulations so that it (ASoCFL) can legall y offer the following

services:

1

. A e ria l p h o t og r a p h y a n d /o r v i d e o f o r p ub l i c a n d / o r p ri v at e u s e i n c l ud i n g

r e a l es t a t e

, a rc h i t e ct u r e

, construction, la n d s u r ve y i n g

, land mapping, land

acquisition, crop surveying, e n g i n ee r i n g a n d o t h e r r e l at e d p ro fess i on a l

acti v i ti es

. 2

. A e ria l v i d e o a nd / o r p h o t og r a p h y f o r p u b li c a n d / o r p ri v at e u s e i n c l ud i n g

t e l ev i s i o n

, p ub l i c eve n t s

, ci n em a t ogr ap h y a n d n ew s gathering

. 3

. A e ria l i n s p e ct i o n / p h o t ogr ap h y o f r es i d e n t i al/co mme rc i a l s tr u c t u r e s un d e r

c o n tra c t w it h t h e o w n e r s o r l oca l go ve r n me n t a u t h o r i t y

. 4. Aerial inspection/photography of residential/commercial utility infrastructure

including but not limited to electrical power lines, wind turbines, and cell

towers.Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

5

. A e ria l v i d e o / p h o t og r a p h y o r p r o v i d i n g li v e v i d e o fee d t o a ss i s t w i t h se a r c h

a n d r es c u e o p e r at i o n s i n ca se s o f a n eme rg e n c y o r n a t u r a l d i s a s t e r o n l y

w h e n t h e loca l a u t h o r iti e s o r go ve r n m e n t h as r e qu es t e d i t b y c o n t ra c t o r

d o n a ti o n.

6

. T h e a b il i t y t o o ffe r t ra i n i n g t o p e r s o n s i n d i v i d u a ll y o r b e l o n g i n g t o b o t h

p ri v a t e an d or p u b li c org a n i z at i o n s t h a t h a v e i n t e r es t s i n t h e u s e a n d

a pp l ic a t i o n o f U A S f o r t h e p u r p o s e o f t h e s a f e o p e r a t i o n o f U A S t o

e n h a n c e t h e s a fe t y o f t h e N a ti o n a l Air s pa c e S y s t e m ( N A S ) a s we l l a s

f o r t h e p r o t e ct i o n o f t h e p e r s o n s a n d p r o p e r t y.

As described in more detail below, the requested exemption would authorize the

operation of small lightweight UAS un d er controlled conditions in airspace that is 1)

limited 2) predetermined 3) controlled as to access and 4) would provide saf ety

enhancements to the safe operational protocols that will be followed by ASoCF L

. Approval of this exemption would thereby enhance safety ( by reduc ing emissions,

noise, and the potential large scale accidents single engine planes and helicopters

could and would cause) and fulfill the Secretary of Transportation's (the FAA

Administrator's) responsibilities to "...establish requirements for the safe op eration of

such aircraft systems in the national airspace system." Section 333(c) of the Reform

Act.

The Name and Address of Petitioner:

Aerial Services of Central Florida, LLC

Attention: James Partin , Owner

4209 Isle Vista Ave.,

Belle Isle, FL 32812

Phone: 407

- 603

- 1235

Email: aerialservicesofcfl@gmail.com

R e g u l a ti o n s f r o m w h i c h t h e e x em p ti o n i s r e q u es t e d:

1 4 C F R 4 5 .2 3 ( b )

1 4 C F R P a r t 2 1 s u b p ar t H

1 4 C F R 6 1 .11 3 ( a ) & (b)

1 4 C F R 9 1

. 7 ( a )

1 4 C F R 9 1

. 9 ( b ) ( 2 )

1 4 C F R 9 1 .103

1 4 C F R 9 1 .109

1 4 C F R 9 1 .11 9

1 4 C F R 9 1 .121

1 4 C F R 9 1 .15 1 ( a )

1 4 C F R 9 1 .20 3 ( a ) & ( b )Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition 1 4 C F R 9 1 .40 5 ( a )

1 4 C F R 9 1 .40 7 ( a ) ( 1)

1 4 C F R 9 1 .40 9 ( a ) ( 2)

1 4 C F R 9 1 .41 7 ( a ) & ( b )

Introduction

ASoCFL is based in Orlando, Florida. As the owner of ASoCFL I possess more

than 10 years of extensive RC experience and flight hours as a pilot of hobby grade

helicopters , quad copters, and hexi

- copters, for recreational purposes. ASoCFL will

employ the use of a professional le vel UAS known as the DJI Inspire 1, a hobby

grade UAS known as the DJI Phantom 2 , and the prosumer level DJI Phantom 3

with intent to offer commercial services upon approval from the FAA . ASoCFL

requests permission to offer the following services: 1. A e ria l p h o t og r a p h y a n d /o r

v i d e o f o r p ub l i c a n d / o r p ri v at e u s e i n c l ud i n g r e a l es t a t e

, a rc h i t e ct u r e

, construction, la n d s u r ve y i n g , land mapping, land acquisition, crop surveying,

e n g i n ee r i n g a n d o t h e r r e l at e d p ro fess i on a l acti v i ti es

. 2. A e ria l v i d e o a nd / o r

p h o t og r a p h y f o r p u b li c a n d / o r p ri v at e u s e i n c l ud i n g t e l ev i s i o n

, p ub l i c eve n t s

, ci n em a t ogr ap h y a n d n ew s gathering

. 3. A e ria l i n s p e ct i o n / p h o t ogr ap h y o f

r es i d e n t i al/co mme rc i a l s tr u c t u r e s un d e r c o n tra c t w it h t h e o w n e r s o r l oca l

go ve r n me n t a u t h o r i t y

. 4. Aerial inspection/photography of residential/commercial

utility infrastructure including but not limited to electrical power lines, wind turbines,

and cell towers. 5

. A e ria l v i d e o / p h o t og r a p h y o r p r o v i d i n g li v e v i d e o fee d t o a ss i s t

w i t h se a r c h a n d r es c u e o p e r at i o n s i n ca se s o f a n eme rg e n c y o r n a t u r a l d i s a s t e r

o n l y w h e n t h e loca l a u t h o r iti e s o r go ve r n m e n t h as r e qu es t e d i t b y c o n t ra c t o r

d o n a ti o n. 6

. T h e a b il i t y t o o ffe r t ra i n i n g t o p e r s o n s i n d i v i d u a ll y o r b e l o n g i n g t o

b o t h p ri v a t e an d or p u b li c org a n i z at i o n s t h a t h a v e i n t e r es t s i n t h e u s e a n d

a pp l ic a t i o n o f U A S f o r t h e p u r p o s e o f t h e s a f e o p e r a t i o n o f U A S t o e n h a n c e t h e

s a fe t y o f t h e N a ti o n a l Air s pa c e S y s t e m ( N A S ) a s we l l a s f o r t h e p r o t e ct i o n o f t h e

p e r s o n s a n d p r o p e r t y. ASoCFL intend s to offer services to industries such as rea l

e st a te professionals

, home builders, land brokers

, land developers

, construction

companies

, communication tower inspection

, news, television, motion picture

companies, farmers, and other industries as will be r evealed by the natural passing

of time and the rapidly maturing UAS technologies f ollowing e x e mption a nd

a pp r ov a l b y the F AA.

In support of this petition ASoCFL provides hyperlink’s to User M anuals for the DJI

Inspire 1, DJI Phantom 2, and DJI Phantom 3.

Aerial Services of Central Florida’s Proposed Operations Do Not Create

Significant Risks or Hazards

The e x e mption re qu e st would authorize op era tion of the below

- illustrated ult r a

lightweight UAS (s) in ti g ht l y c ont r oll e d a nd limit e d a i r sp ace

. All instances for hire

would take place at p re d e t er min e d area s a w a y fr om g e n era l publi c, a i r po r ts,

h e lipo r ts

, v e hi c ul a r t ra f f ic, a nd within p r op er t y bound ar i e s of the hirer with theirAerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition expressed verbal and or written consent. In addition to following the FAA’s

Conditions and Limitations, ASoCFL h as adopted s afe t y protocols and controls to

avoid and prevent public hazard, as well as manned aircraft hazards /cat astrop he by

following a self

- imposed process detailed later herein

.

The proposed commercial use of UAS(s) as compared to commercial use of

manned single engin e planes, helicopters, and not to mention manned climbing for

tower ins pections offers a significantly safer alternative to the health and welfare of

the public. I n a Presidential Memorandum published February 15, 2015; President

Obama said in part, “ As compared to manned aircraft, UAS may provide lower

- cost

operation and augment existing capabilities while reducing risks to human life.

Estimates suggest the positive economic impact to U.S. industry of the integration

of UAS into the NAS could be substantial and likely will grow for the foreseeable

future. ”

The UAS’s:

Each of the UAS outlined below includes a GPS mode that allows the UAS to hover

in place if communication is lost and will subsequently return back to its launched

position or “Home” position. In a ddition; when the UAS reaches 25 % of usable battery

power, the PIC will return th e UAS to it’s Home position, if necessary the on board

computer will retu rn the UAS automatically

.

UAS

- 1: Inspire 1 by DJI

The professional level UAS

- 1 known as the Inspire

- 1 by DJI is equipped with a 4K

camera which is capable of shooting up to 4K video and capture up to 12 megapixel

photos weighing less than seven pounds. If needed please see the attached

Inspire 1 manual for additional specs.Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition Model T600

Weight (Battery Included) 2935 g

Hovering Accuracy (GPS Mode) Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Flight Altitude 4500 m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Mo tor Model DJI 3510

Propeller Model DJI 1345

Indoor Hovering Enabled by default

Operating Temperature Range

- 10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438x451x301 mm

Supported DJI Smart Battery

UAS

- 2: Phantom 2 by DJI

The hobby grade UAS

- 2 known as the Phantom 2 by DJI is capable of shooting up

to 4K video and capture up to 12 megapixel photos utilizing a GoPro 3 HERO

camera all weighing less than three pounds. If needed please see the attached

Phantom 2 manual for additio nal specs.Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition Weight (Battery & Propellers) 1000g

Hover Accuracy (Ready To Fly) Vertical: 0.8m;

Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s

Max Flight Speed 15m/s(Not Recommended)

Diagonal Length 350mm

Flight Time 25mins

Take

- Off Weight ≤ 1300g

Operating Temperature

- 10°C ~ 50°C

Supported Battery DJI Smart Battery

UAS

- 3: Phantom 3 by DJI

The prosumer grade UAS

- 3 known as the Phantom 3 by DJI is equipped with a 4K

camera which is capable of shooting up to 4K video and capture up to 12 megapixel

photos weighing less than three pounds. If needed please see the attached

Phantom 3 manual for additional spe cs.

Weight (Battery & Propellers) 1280g

Hover Accuracy (Ready To Fly) Vertical: 0.1m;

Horizontal: 1.5m

Max Ascent / Descent Speed Ascent: 5m/s; Descent: 3m/s

Max Flight Speed 16m/s(ATTI mode, no wind)

Diagonal Length 590mm (including propellers)

Flight Time 23mins

Take

- Off Weight ≤ 1300g

Operating Temperature 0°C ~ 40°C

Supported Battery DJI Smart BatteryAerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition Self

- Imposed Safety Protocols and Controls

Aerial Services of Central Florida will fully and voluntarily adhere to the safety

guidelines set forth by FAA Policy N 8900.227 Section 14 "Operational

Requirements for UAS ” with the appropriate exemptions for flying a small UAS.

1. No flight will be made with a UA G ross weight exceeding 20 pounds

.

2. Flights will be operated at an altitude of no more than 400 feet Above Ground

Level (AGL) and not more than 200 feet above an elevated platform from which

filming is planned.

3. Operations will be restricted to flights over private property with the permission of

the written and/or oral permission of the property owner

.

4. T h e owner/ o p e r at o r w i l l f il e F A A F or m 771 1

- 1

, o r it s e qu i v al e n t

, a s m o d i f i e d i n

l ig h t o f t h e r e qu es t e d e x em p ti o n

, w i t h t h e a pp r o p r iat e loc a l F l ig h t S t a n d a rd s

D i s tric t O ff ic e ( FS D O ) n o m or e th a n 7 2 h o u r s b u t n o l es s t h a n 4 8 h o u r s f r o m

p l an n e d o p e ra t io n

.

5. T h e PI C a n d V O w i l l h a v e b e e n t ra i n e d i n o p e r a ti o n o f U A S a n d r e c e i v e u p

- t o

d a t e i n f or m a ti o n f or t h e p a rti c u l a r U A S t o b e op e rat e d

.

6. A briefing will be conducted in regard to the planned UAS operations prior to

each day's production activities. It will be mandatory that all personnel who will be

performing duties within the boundaries of the safety perimeter be present for this

briefing.

7. T h e owner/ o p e r a to r w il l o b t a i n ve r b al and or w r itt e n c o n se n t o f al l p e r s o n s

i n v ol ve d w i t h t h e p l a n n e d o p e ra t i o n a n d e n s u r e t h a t o n l y c o n se n ti n g p e r s o n s w i l l

b e allo w e d w it h i n 10 0 fee t o f t h e f li g h t o p e r a t i o n

, and t h e r a d i u s m a y b e r e d u c e d

t o 3 0 fee t b a se d u p o n a n e qu i v al e n t l eve l o f s a fe t y d e t e r m i n a t io n

. W it h t h e

a d v a n c e d p e r m i ss i o n o f t h e FS DO

, o p e r a ti o n s a t c lo se r r a n g e m a y b e a p p ro ve d.

8. Maxi m u m f li g h t ti m e f o r e a c h o p e r at i o n a l f l ig h t w il l b e 2 5 m i n u t es

. F l i g h t s w il l

b e t e r m i n a t e d a t 25 % b a t t e r y p o we r r ese r v e.

9. The UAS will not be operated within 5 NM of an airport or heliport

.

10

. Operations will be restricted to daytime only and weath er conditions equivalent

to VFR

.

11

. Minimum crew for each operation will consist of the UAS Pilot and at least one

Visual Observer (VO), and may include a third, but separate, Camera Operator

(CO).Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition 12. The PIC will brief the property owner about the operation and risk before the

fi rst flight at each new location

.

13. No operation will take place without both a full y charged battery and a Pre

Flight Inspectio n by the PIC to establish the UAS is in condition for safe flight

.

14. T h e PI C a n d V O w i l l b e a b l e t o co mm u n i c at e b y v oic e

, or r ad io a t al l ti mes

.

15. If the UAS loses communications with the remote controller or loses GPS

signal, the UAS will have the capability to return to a pre-determined location

within a designated location and land autonomously.

16

. The UAS will have the capability to abort a flight in case of

emergencies with an automated “Return Home and Land” function.

17

. The UAS will have the capability to abort a flight in case of unpredicted

obstacles, weather, or emergencies such as low battery.

The protocols as outlined above, are the minimum guidelines ASoCFL will obey.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 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 asso ciated with the

aircraf t 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 Secti on 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 UAS. In all cases, an analysis of these criteria demonstrates that the UAS

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 (fixe d wing or rotorcraft) operating with an airworthiness certificate without

the restrictions and conditions proposed. The UAS to be op erated hereunder is less

than 20 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive

materials or flammable liquid fuels, and operates exclusively within a secured and

designated area. Unlike other civil aircraft, operations under this exemption will be

tightly controlled and monitored by both the operator and under the requirements

and in compliance with local public safety requirements. These safety

enhancements 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 UAS,Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition due to its size, speed of operation, location of operation, lack of explosive materials

or flammable liquid fuels, and inability to carr y a substantial external load.

14 C.F.R. § 45.23 (b): Marking of the Aircraft

. The regulation requires: When

marks include only the Roman capital letter "N" and the registration number is

displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches

nor more than 6 inches high, the words "limited," "restricted," "light-sport,"

"experimental," or "provisional," as applicable. Even though the UAS will have no

airworthiness certificate, an exemption may be needed as the UAS will have no

entrance to the cabin, cockpit or pilot station on which the word “Experimental” can

be placed. Given the size of the UAS, two-inch lettering will be impossible. The

word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

US Department of Transportation February 20, 2015 The equivalent level of safety

will be provided by having the UAS marked on its fuselage as required by §45.29 (f)

where the pilot, observer and others working with the UAS will see the identificatio n

of the UAS as “Experimental.”

14 C.F.R. § 61.113 (a) and (b): Privat e Pilot Privileges and Limitations: Pilot in

Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private

pilot certificate may act as a pilot in command of an aircraft that is carrying

passengers or property for compensation or hire. The pr oposed UAS operations

may achieve an equivalent level of safety as achieved by current Regulations

because the petitioner’ s UAS (s ) do not carry any pilots or passengers or property.

The risk associated with the operation of a UAS is far less than the risk levels

inherent in the commercial ac tivities outlined in 14 CFR 61.

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 det ermining airworthiness. Given the size

of the aircraft for maintenance and use of safety checklists prior to each flight, an

equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9

(b) (2) provide s: No person may operate a U.S. registered civil aircraft ... (2) For

which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this

chapter, unless there is available in the aircraft a current approved airplane or

Rotorcraf t Flight Manual, approved manual material, markings, and placards, or any

combination thereof. The UAS, 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 th e PIC flying the UAS will have

immediate access to it.Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition 14 C.F.R . § 91.103: Preflight Action. This regulation requires each pilot in

command to take certain actions before flight to insure the safety of flight. As FAA

approved rotorcraft flight manuals will not be provided for the aircraft an exemption

will be needed. The PIC wi ll take all actions as outlined above; including but not

limited to a thorough pre

- flight inspection of the UAV, reviewing weather, flight

battery requirements, landing and takeoff distances

, and aircraft performance data

before initiation of fli ght

.

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may

operate a civil aircraft (except a manned free balloon) that is being used for flight

instruction unless that aircraft has fully functioning dual controls. UAS and remotely

piloted aircraft, by their design do no t 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 approved exemptions for flight

training without fully functional dual controls for a number of aircraft and for flight

instruction in experimental aircraft. The equivalent level of safety is provided by t he

fact that neither a pilot nor passengers will be carried in the aircraft and by the size

and speed of the aircraft.

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. As this exemption is for a UAS that is a helicopter and the exemption requests

authority to operate at altitudes up to 400 AGL, or not more than 200 above an

elevated platform from which filmin g is planned, an exemption may be needed to

allow such operations. As set forth herein, the UAS will never operate at higher than

400 AGL with the exception that in circumstances where the UAS is used to survey

or photograph a structure whose height exceed s 400 feet AGL, the UAS will not be

operated more than 200 feet above the highest point on the structure. It will

however be operated in a restricted area with security perimeter, where buildings

and people will not be exposed to operations without their p revious consent. The

equivalent level of safety will be achieved given the size, weight, and speed of the

UAS as well as the location where it is operated. No flight will be taken without the

permission of the property owner or local officials. Because of the advance notice to

the property owner and participants in the filming activity, all affected individuals will

be aware of the planned flight operations. Compared to flight operations with aircraft

or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the

lack of flammable fuel, any risk associated with these operations is far less than

those presently presented with conventional aircraft operating at or below 500 AGL.

In addition, the low- altitude operations of the UAS will ensure separation between

these UAS operations and the operations of conventional aircraft that m ust comply

with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person

operating an aircraft to maintain cruising altitude by re ference to an altimeter that is

set “...to the elevation of the departure airport or an appropriate altimeter settingAerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition available before departure.” As the UAS may not have a barometric altimeter, but

instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent

level of safety will be achieved by the operator, pursuant to the safety check list and

live flight data monitoring, confirming the altitude of the launch site shown on the

GPS altitude indicator before flight.

14 C.F.R. § 91.151(a) : Fuel Requirements for Flight in VFR Conditions

. Section

91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is

enough fuel to fly to the first poi nt of intended landing, and, assuming normal

cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At

night, to fly after that for at least 45 minutes.” The petitioner believes that an

exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions.

Operating the UAS in a tightly controlled area where only people and property

owners or official representatives who have signed waivers will be allowed does not

produce the type of risks that Section 91.151(a) was in tended to alleviate given the

size and speed of the small UAS. The petitioner believes that an equivalent level of

safety can be ac hieved by limiting flights to 25 minutes or 25% of battery power

— whichever happens first. This restriction would be more th an adequate to return the

UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and

Registration

. The regulation provides in pertinent 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 paragrap h (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 passengers or crew. The UAS fully

loaded w eighs well under the proposed 20 -lb

. limit and is operated withou t an

onboard pilot. As such, there is no ability or place to carry certification and

registration documents within or on the UAS to display them as contemplated

. An

equivalent level of safety will be achieved by keeping these documents at the

ground cont rol point where the PIC flying the UAS will have immediate access to

them, to the extent they are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance

Inspections. These regulations require that an aircraft op erator 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 that these

sections and Part 43 apply only to aircraft with an airworthiness certificate, these

sections will not apply to the petitioner. Routine m aintenance will be accomplished

by the owner/ operator pursuant to the flight manual and operating handbook. An

equivalent level of safety will be achieved because the UAS is very limited in size

and will carry a small payload and operate only in restricted areas for a limited

period of time. If mechanical issues arise the UAS can land immediately and will beAerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition

Aerial Services of C entral Florida , Orlando, FL

– Section 333 Exemption Petition operating from no higher than 400 feet AGL. The PIC will ensure that the UAS is in

working order prior to initiating flight, perform required maintenan ce, and keep a log

of any maintenance performed. Moreover, the PIC 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. An equivalent level of safety wi ll be achieved

because maintenance and inspections will be performed in accordance with the

UAS Manufacturer's User Manual. As outlined above , the PIC will ensure that the

UAS is in working order by completing the pre

- flight inspection of the UAS prior to

initiating flight and will perform requir ed maintenance needed.

Summary:

ASoCFL will not operate UAS (s) near airports, t he locations where ASoCFL will

conduct it’s services will be both limited and predetermined

, wh ich will allow for a

controlled env ironment to operate safely while greatly reducing risk

. By allowing

ASoCFL to conduct business with a UAS, it will help the Central Florida economy

and benefit many other industries including private citizens to market their homes;

that have not been able to afford to do so prior to UAS technologies

. Furthermore,

ASoCFL’s UAS’s are considerably light er than the alternative which could be a

helicopter or small plane carrying explosive flammable fuels. ASoCFL employs the

use of UAS’s, which will operate up to 25 minutes powered by a battery. Therefore,

the UAS’s used by ASoCFL will t ypically have a flight time of 10

- 15 minutes at one

time, as most photos and video are easily obtained in this flight time window. The

likelihood of injury or even death with a s mall UAS compared to a large manned

aircraft is greatly reduced.

Granting Aerial Services of Central Florida ’s request for exemption comports with

the Secretary of Transportation’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] i n

the national airspace system” under Section 333(c) of the Reform Act speci fic to the

use of UAS's as proposed herein . Further, ASoCFL will conduct operations in full

compliance with the protocols described herein or as otherwise established by the

FAA.

Please contact me should any additional information be required to satisfy an

approval.

Sincerely,

James D. Partin

1 App endix

- A

– DJI Inspire 1 User Manual

2 Appendix

- B

– DJI Phantom 2 User Manual

3 App endix

- C

– DJI Phantom 3 User Manual