Clinton	E.	Guthrie

5026	Cameron	Rd Birmingham,	AL	35242

July	20,	2015

V IA	US	MAIL	or	ELECTRONIC	MAIL :

U. S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Avenue,	SE Washington,	DC	20590

Re:	Exemption Request	under	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the FAA	Regulations	and	certain	parts	of	the	FARs.

Dear	Sir	or	Madam:

INTRODUCTION	AND	INTERESTS	OF	PETITIONER

Pursuant	to	Section	333	of the	FAA	Modernization	and	Reform Act	of 2012	and	t he requirements	 contained	 within	 14	 C.F.R. Part 11, I	 hereby	 request an	 exemption from	 Federal	 Aviation	 Regulations	 (FARs)	 detailed	 below	 for my	 3D	 Robotics	 Inc. (3DR)	X 8+	unmanned	aircraft	system (UAS)

.

SUPPORT	OF	REQEUST The	 requested	exemption	would	 support the use	 of my UAS for	 commercial	aerial photography,	 videogra phy,	inspection	 of private	and	 commercial property ,	as	well as	 land	 and	 timber	 management. The	 3DR X8+	 system consists	 of	 a	 lightweight battery	operated	aircraft	wei ghing	less	than	7	pounds ,	ground	based	computer and

handheld	controller,	and	associated	communications	and imaging	equipment.

REASONS	WHY THIS	REQUEST	WOULD	BE	IN	THE PUBLIC	INTEREST

A camera	is	carried	by	the UAS that	allows	it	to	conduct	precision phot ography	and

inspection .	 The	 high

- resolution images,	 videos	 and data	 will	 provide necessary information	for	my	business	needs	and	those	of	my	clients to	maintain	and	inspect property,	timber,	crops,	and structures without	disturbing	surface	activities.

REASONS	WHY THIS	REQUEST WOULD	NOT AFFECT PUBLIC	SAFETY

The UAS will	 be	 operated	 in	 the	 field	 with	 both	 a	 Pilot	 in	 Command	 (PIC)	 and	 a ground

- based	Visual	Observer	(VO)	in	accordance	with	the	FAA	Policy	N	8900.227 Section	 14	 "Operational	 Requirements	 for	 U AS"	 with	 the	 following	 additional

operating	restrictions:

1. All	operations	will	occur	in	Class	G	air space	at	no	more	than	400ft	AGL.

2. Operations	will	be conducted over	private property only with	the permission

of	the	landowner.3. All	required	permits	will	be obtained	from	state	and	local government prior to	operation

. 4. The	aircraft	will	not	be	operate d	over	dense	urban	or	populated	areas.

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

6. The	aircraft	will	not	be	operated	at	air	shows	or over	an	open

- air	assembly	of people.

7. The	aircraft	will	not	be	operate d	over	heavy	traffic	roads.

8. Operations	will	be	limited	to	day	and	v isual	meteorological	conditions.

9. The	UAS will	remain	within	visual	line	of	sight	at	no	greater	than 400’ above ground	le vel of	the	PIC	at	all	times.

10. While	the	aircraft	is	airborne,	the	VO	will	be	positioned	w ithin	voice	distance range	of	the	PIC.

The	 PIC	 and	 VO	 will	 perform routine maintenance and	inspections on	 the	 sys tem along	with	following	routine	safety	procedures	an d	pre

- flight	checklist	procedures.

We	submit	that	the	combination	of	strict	operation	under	the	guidelines	established in	 8900.227	 and	 the	 aircraft's	 light	 weight,	 historically	 demonstrated	 flight performance ,	 and	 a responsible flight	 crew,	 the	 FAA	 can	 ha ve	 confidence	 that	 the

operation s will be	conducted	in	a	safe	manner	at	all	times

.

NAME	AND	ADDRESS	OF	PETITIONER

The	name	and	contact information	of	the applicant	are:

Clinton	E.	Guthrie

5026	Cameron	Rd Birmingham,	AL	35242

SECTIONS	OF	14	C.F.R.	FROM WHICH	GUTHRIE	SEEKS	EXEMPTION The	regulations	from	which	the	exemption	is	requested	are	as	follows:

14	CFR	Part	21

14	CFR	91.203 14	CFR	45.23,	45.29 14	C.F.R.	91.7(a)

14	CFR	91.9 14	CFR	61.113(a)	&	(b),	61.133(a)

14	CFR	91.109,	91.119

14	CFR	91.121,	91 .151 14	CFR	Subpart	E	(91.401

- 91.417) FAA	Policy	8900.227	Paragraph	16(c)(4)	and	Paragraph	16(e)(l)

EXTENT	OF	RELIEF	AND	REASON	GUTHRIE	SEEKS	RELIEF Including,	 specific	 request	 for	 extension	 of	 relief	 from	 these	 regulations	 for	 the following	reasons:14 C.F.R.	 91.7( a)	 Civil	 aircraft	 airworthiness

- An	 equivalent	 level	 of	 safety will	be	provided	given	the	size	of	the	aircraft	and	the	requirements	contained in	 the	 Aircraft	 Information/Owner’s	 Manual	 for	 maintenance	 and	 use	 of safety	checklists	prior	to	eac h	flight.

14	 C.F.R.	 91.119(c)

- Over	 other	 than	 congested	 areas,	 o perations	 of	 the aircraft	will	be	conducted	at	distances	less	 than	500	 feet	 from	participating persons,	vessels,	vehicles	or	structures	that	perform	an	essential	function	in

connection	wit h	these	special	purpose	operations.

14	C.F.R.	91.121	Altimeter	settings

- Altitude	of	the	aircraft	will	be	provided to	the	PIC	via	radio	communications	telemetry	data	link,	which	links	from	the aircraft	to	the	PIC	for	active	monitoring	of	the	aircraft’s altitude.

14	C.F.R.	91.151(b)	Fuel	requirements	for	flight	in	VFR	conditions

- The UAS will	 not	 begin	 flight	 unless	 (considering	 wind	 and	 forecast	 weather conditions)	 there	is	enough	 fuel	 (battery	 voltage)	 to	 fly	 to	 the	 first	point	 of attending	landing	a nd,	assuming	normal	cruising	speed,	to	fly	after	that	for	at

least	two	minutes.

14	 C.F.R.	 91.405(a)	 Maintenance	 requested,	 14	 C.F.R.	 91.407(a)	 Operation after	 maintenance,	 preventative	 maintenance,	 rebuilding	 or	 alteration,	 14 C.F.R.	 91.409(a)	 Inspection s,	 14.	 C.F.R. 91.417(a),	 maintenance	 records

- Routine	maintenance,	inspections	and	 repairs	will	 be	maintained	 to	ensure that	the	UAS	remains	in	optimum	operating	condition	per	details	outlined	by the	manufacturer	and	as	new	information	and	guidelines	may be	updated.

CONCLUSION

As	 set	 forth	 above, I	 hereby	 seek an	 exemption	 pursuant	 to	 14	 C.F.R.	 11.61	 and

Section	 333	 of	 the	 FAA	Modernization	and	Reform	Act

, which	will	 pe rmit	 the	 safe operation	 of	 a UAS	 commercially,	 for	 the	 special	 purpose	 of	 conducting	 aerial photography	 and	 videography	 along	 with	 aerial	 inspections of	 private	 and commercial	 properties.	 By	 granting	 this Petition,	 the	 FAA	 Administrator	 will	 be fulfilling	 the	 Congressional	 mandate	 of	 the	 FAA	 Mo dernization	 and	 Reform	 Act	 of 2012,	 while	 also	 advancing	 the	 interests	 of	 the	 public,	 by	 allowing me to	 safely,

efficientl y	and	economicall y	operate	my UAS	commercially	within	the	NAS.

Respectfully	submitted,

Clinton	E.	GuthrieSUMMARY	THAT	CAN	BE	PUBLISED	IN	THE	FEDERAL	REGISTRAR

Clinton	 E. Guthrie seeks	 exemption	 from	 the	 requirements	 of	 14	 C.F.R.	 91.7(a), 91.119(c),	 91.121,	 91.151(b),	 91.405(a),	 91.407(a),	 91.409(a )	 and	 91.417(a).	 This exemption	would	permit Guthrie	to	operate	his UAS	to	safely	collect	various	 forms of	aerial	images	and	video	for	commercial	use.

14	CFR	Part	21

14	CFR	91.203

14	CFR	45.23,	45.29 14	C.F.R.	91.7(a)

14	CFR	91.9 14	CFR	61.113(a)	&	(b), 61.133(a)

14	CFR	91.109,	91.119

14	CFR	91.121,	91.151 14	CFR	Subpart	E	(91.401

- 91.417) FAA	Policy	8900.227	Paragraph	16(c)(4)	and	Paragraph	16(e)(l)

Including,	 specific	 request	 for	 extension	 of	 relief	 from	 these	 regulations	 for	 the following	reasons:

1 4	 C.F.R.	 91.7( a)	 Civil	 aircraft	 airworthiness

- An	 equivalent	 level	 of	 safety will	be	provided	given	the	size	of	the	aircraft	and	the	requirements	contained in	 the	 Aircraft	 Information/Owner’s	 Manual	 for	 maintenance	 and	 use	 of safety	checklists	prior	to	ea ch	flight.

14	 C.F.R.	 91.119(c)

- Over	 other	 than	 congested	 areas,	 o perations	 of	 the aircraft	will	be	conducted	at	distances	less	 than	500	 feet	 from	participating persons,	vessels,	vehicles	or	structures	that	perform	an	essential	function	in

connection	wi th	these	special	purpose	operations.

14	C.F.R.	91.121	Altimeter	settings

- Altitude	of	the	aircraft	will	be	provided to	the	PIC	via	radio	communications	telemetry	data	link,	which	links	from	the aircraft	to	the	PIC	for	active	monitoring	of	the	aircraft’s altitude.

14	C.F.R.	91.151(b)	Fuel	requirements	for	flight	in	VFR	conditions

- The UAS will	 not	 begin	 flight	 unless	 (considering	 wind	 and	 forecast	 weather conditions)	 there	is	enough	 fuel	 (battery	 voltage)	 to	 fly	 to	 the	 first	point	 of attending	landing and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at

least	two	minutes.

14	 C.F.R.	 91.405(a)	 Maintenance	 requested,	 14	 C.F.R.	 91.407(a)	 Operation after	 maintenance,	 preventative	 maintenance,	 rebuilding	 or	 alteration,	 14 C.F.R.	 91.409(a)	 Inspectio ns,	 14.	 C.F.R. 91.417(a),	 maintenance	 records

- Routine	maintenance,	inspections	and	 repairs	will	 be	maintained	 to	ensure that	the	UAS	remains	in	optimum	operating	condition	per	details	outlined	by the	manufacturer	and	as	new	information	and	guidelines	may be	updated.