Quentin E. Tyler 18324 We st Ocotillo Ave Goodyear, AZ 85338

28 AUG 2015

To whom it may concern at the FAA: I currently have owned a DJI Phantom 2 for over 2 years and I have approximately 300 hours of accident free flight time as a hobby ist. Additio nally , I have over 20 years of experience with radio controlled model aircraft. I currently work as a technical supervisor for the Phoenix Fire Department, and fully understand the seriousness of safety. I have been an avid photographer for many years and being able to fly a UAS with a camera has been a natural extension of my photography and videography. All of my work has been in visual line of site. I have no desire nor do I need to ever operate the UAS in any manner than within visual line of site. I h a ve recently upgraded to a DJI Phantom 3 which allows for a longer flight time and is equipped with a better quality camera for still photos and videos. My plan is to pursue a commercial business venture to take still photos or produce videos at the reque st of potential clients . In all cases I will receive permission prior to any performed work and will always keep safety as the number one consideration when flying the UAS.

Quentin Tyler will be the only Pilot in Command using the UAS.Quentin E. Tyler 18324 We st Ocotillo Ave Goodyear, AZ 85338

To the Federal Aviation Authority (FAA),
I hereby request exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 9 1.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).
I support my request with the following information:
I plan to operate a UAS, the DJI Phantom 3 , which is comprised of an unmanned aircraft and a transportable ground station. The DJI Phantom 3 is referred to as a quad

- copter with a maximum gross weight of about 3 pounds . It is equipped with four rotors that are driven by electric motors powered by a battery. The UAS has a maximum airspeed of 22 m/s. The quad has a built in high definition camera. I plan to operate the UAS over various areas within the United States . I make the following representations of operational enhancements which I propose to abide by to ensure this exe mption will provide a level of safety at least equal to existing rules: • I will only operate in reasonably safe environments that are strictly controlled, and are away from power lines, elevated lights, airports and actively populated areas. • I will co nduct extensive preflight inspections and protocols, during which safety carries primary importance.
I state that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, an exemption from 14 CFR part 21, Sub part H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required),Quentin E. Tyler 18324 We st Ocotillo Ave Goodyear, AZ 85338

subject to certain conditions and limitations, is warranted and meets the
requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333).

I request an exemption from § 45.23 Marking of the aircraft because this UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Furt her, I state that two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of th is, I state that I will mark my UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that I or anyone assisting me as a spotter will see the markings.
I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be requi red and should be granted since they only apply to aircraft with an airworthiness certificate. However, I state that as a safety precaution I will perfo rm a preflight inspection of my UAS before each flight as outlined in my operating documents.

UAS Pilo t in Command (PIC) I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry any pilots or passengers. Further, I state that, while helpful, a pilot license will not ensure remote control piloting skills. I further indicate that the risks of operating a UAS are far less than the risk levelsQuentin E. Tyler 18324 We st Ocotillo Ave Goodyear, AZ 85338

inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus I request an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in command.
Regarding UAS operational training, I state I have flown numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this UAS’ performance under different temperature and weather conditions.
UAS Operating Parameters I will abide by the following additional operating conditions under this exemption:
• Operate my UAS below 2 00 feet and within a radius distance of 1000 feet from the controller to both aid in direct line of sight visual observation. • Operate the UAS for no more than 20 m inutes per flight. • Land my UAS prior to the manufacturer’s recommended minimum level of battery power. • Operate my UAS only within visual line of sight (VLOS). • Use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost.Quentin E. Tyler 18324 We st Ocotillo Ave Goodyear, AZ 85338

• Conduct all operations under my own personal and flight safety protocols contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance my safety protocols. • Contact respective airports if operations will be within 5 miles to advise them of my estimated flight time, flight duration, el evation of flight and other pertinent information. • Always obtain all necessary permissions prior to operation. • Have procedures in place to abort flights in the event of safety breaches or potential danger.
I state that § 91.7(a) prohibits the operat ion of an aircraft without an airworthiness certificate. I assert that since there is currently no certificate applicable to my operation, this regulation is inapplicable.
I state that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, howe ver since there are no pilots or passengers on board his aircraft and given its size, this regulation is inapplicable. I further indicate an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station.
I state that § 91.119 prescribes safe altitudes for the operation of civil aircraft, but that it allows helicopters to be operated at lower altitudes in certain conditions.
I state that I will not operate this UAS above the altitude of 200 feet above groun d level (AGL) and will also only operate in safe areas away from the public andQuentin E. Tyler 18324 We st Ocotillo Ave Goodyear, AZ 85338

traffic, thus “providing a level of safety at least equivalent to or below those in relation to minimum safe alt itudes. I assert that given the size, weight, maneuverability, and speed of my UAS, an equivalent or higher level of safety will be achieved.
I indicate that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electronic GPS with a barometric sensor.

Public Interest
I state that aerial videography and photography for geographical awareness and for real estate marketing has been around for a long time through manned fixed win g aircraft and helicopters, but for small business owners, its e xpense has been cost

- prohibitive. Granting this exemption to myself would allow me to provide this service at a much lower cost.
Further, I would like to indicate my small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft.
I would also like to state that the operation of my UAS w ill minimize ecological damage being battery operated.
(end of petition)Additionally I have contacted my insurance carrier and once these exemption s

are approved by the FAA to legally fly the UAS commercially I will be able to purchase damage and liability insurance for the UAS operations.

Thank You , Quentin E. Tyler