1 U.S Department of Transportation

Docket Management System

1200 New Jersey Avenue, S.E.

West Building Ground Floor, Room W12

- 140

Washington, D.C 20590

Petition for Exemption to section 333 on behalf of the Petitioner; Submitted by

Attorney Jerald A. Lavin , Jerald A. Lavin, Ltd

324 Osprey Point Drive

Osprey, Florida 34229

941 320 0077

lavin77@comcast.net

May 8, 2015

Petitioner:

Matthew D. Lavin a/k/a Aerography

1350 45 th Avenue #B

Capitola, CA. 95010

Tel. 917 509

- 3 201

In re: 333 petition; Petitioner is making application via this petition to the FAA to grant a Certificate of Authorization (COA) to petitioner who is compliance with and meets and shall meet all requirements as stated and required pursuant to

section 333 of “the act” to fly his UAS in the NAS as prescribed and required by

the FAA

Dear Sirs and or Madam:

Matthew D. Lavin a/k/a Aerography a USA citizen, Petitioner, by this petition wishes to apply for authorization from the FAA Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Matthew D. Lavin a/k/a Aerography a USA citizen, owner of a small UAS equipped to conduct aerial photography and videography, hereby applies for an exemption from the l isted Federal Aviation Regulations (“FARs”) to allow commercial operation of UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be2 established by the FAA as required by Section 333.1 The proposed exempti on, if granted, would allow Matthew D. Lavin a/k/a Aerography to conduct commercial operations of small unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333. Statutory A uthority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the

FAA “shall determine if certain unmanne d aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congres s made it clear that Section 333 provides a mechanism for “expedited operation authorization” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations.333 provides a mechanism for “expedited operatio n authorization” if several factors are met. Approval of the exemption for petitioner will allow commercial operation of the Gryphon Dynamics 900, a propriety design, for the Videography and Photography industries and (2) the construction industry nationwi de in Class G airspace under 200 feet AGL nationwide, or as otherwise prescribed in an ATO issued COA. The requested exemption should be granted because operation of small UAS, weighing approximately 18 lbs. (8 kg.), inclusive of battery and payload, condu cted in the strict conditions outlined below, will provide an equivalent level of safety, while still allowing commercial operations. The lightweight aircraft covered by the exemption is safer than conventional operations conducted with helicopters and fix ed

- wing aircraft weighing thousands of pounds and carrying highly flammable fuel, and operating in close proximity to the ground, power lines, transmission towers, pipelines, and people. The seven factors Congress directed the FAA to consider when approvin g Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight

– each supported request. In particular, the aircraft is small, and will operate at slow speeds, and close to the ground at 200 AGL or lower in order to more safely and efficiently conduct inspections that would otherwise involve a risk of death to the inspectors. The substantial increase of safety and decrease of risk to human life, coupled with the low risk use of UAS to conduct these operations, weigh heavily in favor of granting the exemption.

Proposed Operations of The UAS

The requested exemption will permit petitioner to operate the Gryphon Dynamics 900, a proprietary desig n, with a maximum weight of approximately 18 lbs. (8 kg.), inclusive of batteries and technical payload. This rotorcraft operates at a speed of no more than 35 knots and has the capability to hover and move in the vertical and horizontal planes

simultaneou sly.3 The UAS will use the following:

· GPS/Autopilot System: DJI WooKong

- M, with its accompanying Main Controller (MC), Internal Measurement Unit (IMU), and GPS.

· Receiver: Spektrum AR8000 2.4ghz DSMX.

· Datalink: DJI iOSD Mark II 2.4 Ghz, which displ ays power voltage, flight velocity, height, distance from the home point, horizontal attitude and GPS satellite number acquired to make the location calculation.

· Transmitter 1 (Tx1): Spektrum DX8, used by the UAS operator to control the UAS.

· Transmit ter 2 (Tx2): Spektrum DX8, used by the camera operator to control the gimbal

and camera.

Please refer to Exhibits 1

- 7 for further information regarding the UAS. Details regarding the design and assembly of the UAS are being submitted confidentially, due t o the proprietary nature of the UAS. The petition and the supporting documentation in the

Exhibits are hereinafter referred to as the operating documents ʼ

The Crew

The crew will consist of a pilot in command (PIC), and a visual observer (VO) The PIC, an d VO will have been trained in operation of UASs generally. The PIC will have completed, at a minimum, 40 hours of UAS flight training with this specific UAS prior to operations, and will be required to participate in annual training thereafter.

Flig ht Conditions

The UAS will be used for the cinematography, photography and construction industries. It will be flown in Class G airspace nationwide under 2 00 feet above ground level (AGL) and under controlled conditions over property that is restricted as stated below under, Flight Operations. Petitioner will work with the local FSDO when planning operations. The flight crew will always make a safety assessment of the risk of every operation, and will only operate when it is determined that no hazards are present.

Flight Operations

The purpose of every UAS flight will be to conduct safe, accurate, and efficient (i) cinematography and photography or (ii) site inspections for the construction industry in Class G airspace nationwide. The PIC will be respons ible for flying the UAS and will use a Spektrum DX 8 transmitter. The PIC will have visual contact with the UAS at all times and will have available on screen display to observe telemetry data, including battery4 power and flight altitude. The main purpose of the OSD with the telemetry information is to set an audio signal for when the voltage on the battery is running low.

Prior to the day of an operation, the flight crew will conduct a site inspection. The flight

crew will look for obstructions in the fil ming or construction area, and determine a safe flight plan. The flight crew will also make a note of any public access points in the general area, where nonparticipating individuals could access the operational area. The flight crew will adapt their fligh t plan to avoid these areas.

On the day of an operation, the flight crew will cone off the flight operational area (if not already roped off),. The only individuals allowed within the flight operational area will be participants actors, crew members, or construction workers. All other nonparticipating

individuals and vehicles will be outside the sectioned

- off area. Prior to each operation, the flight crew will conduct a safety briefing with all individuals who will be in the flight operational area.

The f light crew will set a "home area" that the UAS will launch from and return to. The

area will have a ten

- foot radius and be marked off with traffic cones. The flight crew will

stand outside this area.

The flight crew will conduct a pre

- and post

- flight in spection, as laid out in Dynamics 900 Inspection Procedures, The flight crew will also conduct an inspection flight each week, going through both the pre

- and post

- flight procedures to ensure that the Gryphon Dynamics 900 is in a safe condition. In the unl ikely event of emergency or a lost link, the UAS will be equipped with an emergency "return to home" feature as part of the DJI WooKong

- M flight control. If there is a lost link, the WooKong

- M will be programmed to rise 30 meters (99 feet) instantaneously (not to exceed a maximum altitude of 200 feet AGL), travel horizontally to the home area, and land. For more information regarding the emergency fail safe methods, please refer to the WooKong

- M User Manual (Exhibit) to this petition. The failsafe section b egins on page 23 of that document. Flights will be terminated at 20% of battery life. Currently, the Gryphon Dynamics 900 battery is limited to approximately 13 minutes of flight time. We will use an onboard telemetry to monitor data, including battery lif e. The telemetry will send an audio signal when the battery depletes to 20% of remaining power.

Aircraft and Equivalent Level of Safety

Petitioner proposes that the exemption apply to UAS that have the characteristics and that operate with the limitatio ns proposed herein. These limitations provide for a level of safety at least equivalent to or higher than manned aircraft operations under the current regulatory structure. The section below identifies the limitations and conditions to which petitioner agr ees to be bound when conducting commercial operations under a grant of this petition.5 Proposed Conditions of the Exemption

1. The UAS will weigh approximately 18 lbs. (8 kg.), inclusive of battery and technical payload.

2. UAS operations under this ex emption will be limited to conducting operations for the purpose of cinematography, photography and construction site inspections in Class G airspace nationwide.

3. Flights will be operated within line of sight of a pilot (PIC) and visual observer (VO).

4. Flights will be operated at an altitude of no more than 200 feet AGL, as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must
be in feet AGL.

5. The UAS will not be flown at an indicated airspeed exceedin g 35 knots and in any
event never in excess of 87 knots.

6. Minimum flight crew for each operation will consist of the UAS pilot in command (PIC) and a visual observer (VO).

7. The PIC will have, at minimum, 40 hours of training on the UAS to be operated under this grant before accepting commercial operations.

8. The petitioner will not permit any PIC to operate unless the PIC meets its qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent
with how the UAS w ill be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels,

vehicles and structures.

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

d ay ʼ s activities. It will be mandatory that all personnel who will be performing duties in connection with the operations be present for this briefing.

12. Prior to each flight, the PIC will inspect the UAS, including the Ground Control Station, to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects thesafe operation of the UAS, the PIC will not operate the UAS until the necessary maintenance has been performed and the UAS is found to be in a condition

for safe fl ight. All maintenance and alterations will be properly documented in the aircraft

records.

13. Petitioner will conduct a functional flight test on any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristic s, e.g. replacement of a flight critical component. The PIC who conducts the functional test flight will make an entry in the aircraft records.6 14. The petitioner will carry out its maintenance, inspections, and record keeping requirements, at the direct ion and under the supervision of the UAS manufacturer. Maintenance, inspection, alterations, and status of replacement/overhaul component parts will be noted in the aircraft records, including total time in service, description of work accomplished, and th e signature of the manufacturer, authorizing the return of the UAS to service. The manufacturer will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

15. When conducting operations for the videography and photography industry, outside of the exemption, petitioner will submit a written Plan of Activities, and any additional necessary paperwork, to the FSDO at least one day before the proposed operations begin.

16. The UAS will be ope rated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses.

17. The PIC will not begin a flight unless (considering wind and forecast weather

c onditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAS with 20% battery power remaining.

18. Actual total flight time for each operational flight will result in no less than a 20% battery reserve.

19. The UAS will have the capability to abort a flight in case of unexpected obstacles or emergencies.

20. The UAS will be programmed so that if it loses communication with the ground station or loses its GPS signal, it will return to a pre

- determined loc ation within the planned operating area and land or be recovered in accordance with the operating

documents.

21. If the UAS and its radio control link disconnect during flight, the system ʼ s failsafe protection will be triggered and the multirotor will ret urn to home and land automatically, rather than flying off uncontrollably or landing at an unknown location.

22. The operating documents required under 14 CFR §§ 91.9 and 91.203 will be
maintained and available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request. If a discrepancy exists between the conditions and limitations in the exemption grant and the procedures outlin ed in the operating documents, the grant conditions and limitations will take precedence and will be followed. Otherwise, the petitioner will follow the procedures outlined in its operating documents. If it updates or revises its operating documents, it wi ll present updated and revised documents to the Administrator upon request. If the petitioner determines that any update or revision would affect the basis upon which the FAA granted the7 exemption, then the Petitioner will petition for an amendment to the grant of exemption.

23. Petitioner will obtain written and/or oral permission from the landowners/authorized agents of the landowners over which flights will be conducted.

24. Petitioner will obtain all required permissions and permits from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

25. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteor ological conditions (VMC). Flights will not be conducted under special visual flight rules (SVFR).

26. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations not covered by the grant of exemption

.

27.

• The UAS will not be operated within 5 nautical miles (NM) from an airport having an operational control tower; or

• 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or

• 2 NM from an airport without a published instrument flight procedure or an operational tower; or

• 2 NM from a heliport with a published instrument flight procedure

28. All aircraft operated in accordance with this exemption will be identified by serial

num ber, registered in accordance with 14 CFR part 47, and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

29. Before conducting operations, petitioner will ensure that the radio frequency spectrum used for operation and control of the UAS complies with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

30. The UAS will remain clear and yield the right of way to all manned av iation operations and activities at all times.

31. The UAS will not be operated by the PIC from any moving device or vehicle.

32. The UAS will not be operated over congested or densely populated areas.

33. Petitioner will conduct all flight operations a t least 500 feet from all nonparticipating8 persons, vessels, vehicles, and structures unless one of the following three conditions is

met:

a. Barriers or structures are present that sufficiently protect nonparticipating persons
from the UAS and/or debris in the event of an accident. The petitioner will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAS, the PIC will ensure that flig ht operations cease immediately.

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating c loser to those objects and determined that it does not present an undue hazard.

c. Operations nearer to the PIC, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

36. Petitioner will report any incide nt, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Petitioner will report

accidents to the National T ransportation Safety Board (NTSB) per instructions contained
on the NTSB Web site: www.ntsb.gov

.

Videography and Photography As the FAA has repeatedly recognized in granting other exemptions under Section 333,

the use of a UAS to record video and photography for motion picture and television sets significantly increases the level of safety for both the actors and crew. Currently, filmmakers and photographers use manned aircraft, which can weigh 6,000

lbs. or more. Manned aircraft also, by definition, carry a pilot and other crew. They carry flammable fluids, and require large areas to take off, operate over, and land. By using the Gryphon Dynamics 900, many of these dangerous conditions will be alleviated. The Gryphon Dyn amics 900 weighs 18 lbs. The pilot and flight crew will be safely on the ground rather than several hundred feet in the air. The UAS is powered by a battery, and requires a small area to operate in. The FAA has previously determined that using a
UAS such a s the Gryphon Dynamics 900 will provide a greater level of safety when filming for the motion picture and television industry. Exemption No. 11062.

Construction Inspections Use of a UAS to conduct inspections of construction projects will provide a greate r level of safety than what is currently available. The construction industry has traditionally been very dangerous for workers, both based on the working conditions and equipment used, including helicopters and cranes. Currently, aerial inspections are no t done on many construction projects. Instead, inspections are conducted from the ground, or from within the structure being constructed, giving a limited view of the project. This limits the capabilities of architects and construction crews examining the work that has been done, and could lead to misidentification or failure to identify flaws in the construction.9 Those projects that do incorporate aerial inspections must rely upon manned helicopters or other types of aircraft, devices that can pose a great risk to those piloting and those on the ground below, without providing the most accurate results. Alternatively, using the Gryphon Dynamics 900 to videotape and photograph construction sites will allow the construction crew to gain a better vantage point of the structure. Safety concerns can be better identified and fixed, and the inspectors will be able to gain a more thorough understanding of construction progress. This UAS will be able to provide a quick and cost effective aerial inspection of an entir e jobsite, something that is much more difficult to perform without this technology. The device can be used to check the progress of the project and provide visual information on hard

- to

- reach areas that may not be adequately inspected otherwise without pu tting people in danger. UAS can be equipped with specialized cameras and sensors that provide enhanced detection of other concerns, such as gas leaks, lack of structural integrity. The FAA has previously determined that using a UAS such as the Gryphon Dyna mics 900 will provide an equivalent or greater level of safety than manned flight when inspecting construction sites. Exemption Nos. 11109 and 11204.

The Petitioner Seeks And Requests Relief From The Following Regulations:

RE: Exemption Request Section 3 33 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR 91.7(a); 91.119 (c); 91.121; 91.151 (a) (1); 91.405(a); 91.407(a) (1); 91.409(a) (1)and (2); 91.417(a)&(b)14 CFR 23;14CFR45.23(B); 14 CFR 61.113 (a & b);14CFR91.9 (B

- 2); 14 CFR 91.103 ; 14CFR 91.109;14 CFR 91.203 (a & b); 14CFR 91.405 (a)

It is the request of the petitioner for exemptions listed above in order to legally and safely operate the 18 pound, Gryphon Dynamics 900, Custom Pro

- Built UAS , in the National Airspace System, for the purpose of Unmanned Aerial Photography and Videography for the real estate, construction, and utilities industries for commercial gain and enhancement of Public awareness of UAS operation, and finally enhanced safety for both the General Public and Flight Crews.

It is the petitioners position that the operations for which exemption is requested are safer and more cost effective than using manned aircraft, and for those reasons are in the Public Interest; and would be of benefit in identifying areas of oper ation that may need additional oversight as well as raising public awareness and interest in this rapidly growing facet of aviation. ( Reference Exemption No. 11138 and others to date)

14 CFR 91.7(A) Prohibits the operation of an aircraft without an airwor thiness certificate. Petitioner requests exemption based on previous ( Exemption No. 11138 and others to date)

. The FAA has ruled that this make and model of aircraft (UAS) does not require an

airworthiness certificate.10 14 CFR 91.119(C) States that no p erson may operate an aircraft below the following altitudes: over other than congested areas, an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer

than 500 fe et to any person, vessel, vehicle, or structure.

The petitioner will operate the UAS at an altitude of 200 AGL OR LESS. The operations proposed will operate at maximum of 200 AGL as this usually provides the best angle of capture for the type of photograph y and videography operations proposed.

The UAS is equipped with GPS guided auto pilot with a return home function in case loss of control by the PIC. It is powered by sealed batteries thereby reducing the chance of post impact fire to zero. The UAS utilize d for this exemption is of exceptionally light weight and with camera is less than 55 pounds and shall never exceed the FAA authorized speeds of 87 knots and in most cases the forward speed shall be significantly slower to accomplish the designated purpose of the flight; photo and cinematography.

The petitioner will implement procedures and policies to ensure that any person in the general vicinity of operations will be aware of such operations and ensure that all non

essential personnel are cleared of the area of operations. See Protocols and procedures Section 3.

The petitioner therefore requests relief in part from 14 CFR 91.119(C) 14 CFR 91.121

Altimeter Settings. The petitioner requests relief from 91.121 for the following reason. The UAS is equipp ed with GPS derived altitude capability, however due to the limited altitude requested in this exemption, the FAA has previously granted Exemption for these types of operations. ( Reference Exemption No. 11138 and others to date)

14 CFR 91.151(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) unless there is enough fuel to fly to the first point of intended landing and, assuming normal cruise speeds. (a)(1)During the day to fly for at least 30 minutes. The petitioner requests relief from 91.151(a) due to the fact that the UAS is equipped with a battery and percentage indicator system. The UAS has a flight capability on full charge of approximately 25 minutes depending on camera usa ge and other variables. The petitioner has established that the maximum flight will be 10

- 15 minutes on a fully charged battery. This constitutes landing with approximately 30

- 50 percent battery fuel remaining. The petitioner believes that this follows the spirit and intent of the rule with a great margin of safety. No UAS operations will be conducted at night, as defined by Federal Aviation Regulations.11 14 CFR 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration;

T he petitioner requests relief from 91.407(a)(1) based on the stated following Protocols
and Procedures Section on Maintenance, Return to service after maintenance, and Maintenance records.( Reference Exemption No. 11138 14 and others to date)

CFR 91.409(a )(1)(2) Inspections; The petitioner requests relief from 91.409(a)(1)(2) based on the Protocols and
Procedures Section on Inspections. (Reference Exemption No. 11138 and others to date)

14 CFR 91.417(a)(b) Maintenance records; The petitioner requests relief from 91.417(a) (b) based on the stated following Protocols and Procedures Section; “Flight Operations Protocol” on Maintenance

records

.

14 CFR. 21 and 14 C.F.R. 91 : Airworthiness Certificates, Manuals

14 CFR. 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 UAS meets (and exceeds) an e quivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legisl ation 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 current and projected UAS's meet or exceed ea ch of the elements.

14 CFR. 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 CFR. § 91.9 (b) (2 ) requi res an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. 10 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 CFR. § 91.121 regarding altimeter settings is ina pplicable in so far as my UAS utilizes electronic global positioning systems with a barometric sensor.12 14 CFR. § 91.203 (a) and (b ) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons de scribed above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Matthew Lavin

14 CFR. § 45.23: Marking of the Aircraft

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraf t with dimensions smaller that minimal lettering requirement. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A

and 10700.

14 CFR. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 CFR. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. Grant of Exemption No.11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating the Astraeus UAS would not adversely af fect operations in the NAS or present a hazard to persons or property on the ground. The present minimum requirement of PIC flying a UAS at 200 feet AGL is a sport air license and a current valid drivers license to support the medical requirement

14 CFR. 91.119: Minimum Safe Altitudes. Shall be an exception as the petitioner shall fly 200 feet AGL or less;

14 CFR. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain con ditions. My UAS will never operate at an altitude greater than 200 AGL ; safely below the standard of 400 AGL. I will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in rel ation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

14 CFR. 91.405 (a) ; 407 (a) (1) ; 409 (a) (2) ; 417(a) & (b ): Maintenance Inspections. These Regulation s only apply to aircraft with an airworthiness certificate.

“The Federal Aviation Administration has established an interim policy to speed up airspace authorizations for certain commercial unmanned aircraft (UAS) operators who obtain Section 333 exemption s. The new policy helps bridge the gap between the past process, which evaluated every UAS operation individually, and future operations after we publish a final version of the proposed small UAS rule.”13 “Under the new policy, the FAA will grant a Certifica te of Waiver or Authorization (COA) for flights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line of si ght (VLOS) of the pilots, and stay certain distances away from airports or heliports:”

• 5 nautical miles (NM) from an airport having an operational control tower; or

• 3 NM from an airport with a published instrument flight procedure, but not an operational t ower; or

• 2 NM from an airport without a published instrument flight procedure or an operational tower; or

• 2 NM from a heliport with a published instrument flight procedure

“The “blanket” 200

- foot COA allows flights anywhere in the country except restricte d airspace and other areas, such as major cities, where the FAA prohibits UAS operations. Previously, an operator had to apply for and receive a COA for a particular block of airspace, a process that can take 60 days. The agency expects the new policy

will allow companies and individuals who want to use UAS within these limitations to start flying much more quickly than before”.

“Section 333 exemption holders will automatically receive a “blanket” 200 foot COA. For new exemption holders, the FAA will issue a COA at the time the exemption is approved. Anyone who wants to fly outside the blanket parameters must obtain a separate COA specific to the airspace required for that operation. also in the Public Interest that many of the low level flight operations no w conducted by manned aircraft could be accomplished with these light, fire resistant unmanned aircraft that can operate at a fraction of the cost to both the operator and consumer. These aircraft can be operated without risk of loss of life or limb, witho ut significant financial impact to the operator or any person or property on the ground in the event of the loss of an aircraft. Finally the petitioner believes that granting this exemption would help to further by Administrators process of integration of UAS systems and possibility help to create additional regulations and guidance to be used as these systems become more widely utilized.”

Petitioner meets all requirements to permit FAA approval of commercial UAS operations

and satisfies the criteria artic ulated in section 333 of the Reform Act of 2012including weight, speed, operating capabilities, people in charge

- PIC and Visual Spotter, proximity to airports and populated areas, operation within VLOS and national security. The proposed UAS operations in NAS will benefit the public as a whole by improving safety and reducing risk when performing the same actions of photo and video by elevating human risk to exposure to danger. Further the activity will be covered by appropriate liability insurance for the activity of no less than one million dollars ($1,000,000). In consideration of the foregoing, this petition provides the FAA with adequate information and justification to issue the requested permission to use and fly the UAS for the stated purposes.14 Tha nk you to the FAA in consideration to issue authorization to the petitioner.

Sincerely, Jerald A Lavin, Jerald A. Lavin, Ltd.

May, 8, 2015________________________________________

For the petitioner, Matthew D. Lavin a/k/a Aerography

****** SUPPORTING EX HIBITS******

1. FLIGHT OPERATIONS PROTOCOL; ... a/k/a AEROGRAPHY 2. GRYPHON DYNAMICS 900, ROTORCRAFT
3. GRYPHON DYNAMICS 900 ASSEMBLY INSTRUCTIONS 4. SPEKTRUM Telemetry User Manual
5. SPEKTRUM DX8 Instruction User Manual 6. IOSD (on screen display) User Ma nual
7. WOOKONG

- M Multi

- Rotor User Manual