Petition f or E xemption 14 CFR § 1 1.81 Exemption petition under S EC 3 33

.

Name: Jo hn G uarino, S hufflebox Productions, L LC

Address: 15525 Ku tztown R d. S uite C Ku tztown, PA 1 9530

Phone: 4 84 -6 48 -2 690

Email: info@shuffleboxproductions.com

The s pecific section or s ections o f 1 4 CFR f rom whic h you seek a n exemption;

I am requesting exemption from the following sections of 14 CFR that I believe meet the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95.

I am requesting exemption from § 91.7(a) as it prohibits an operator from using an aircraft without an airworthiness certificate. This regulation is inapplicable becuase there is no certification applicable to the specific uses of my UAS.

I am requesting exemption from § 91.405(a), § 91.407(a)(1), § 91.409(a)(2) and § 91.417(a) and (b). All of these regulations detailing Maintenance Inspections apply only aircrafts with an airworthiness certificate. I will still be performing all maintenance and pre-flight regulations detailed in this agreement and the DJI Phantom manual.

I am requesting an exemption from § 91.119. The regulations in this section define the minimum safe altitudes for general aerial vehicles. My UAS will be flying no higher than 300 feet above ground level and will at no point be in congested or high traffic areas. Additionally, the maneuverability of the UAS will allow for a level of safety an equivalent to those in relation to minimum safe altitudes.

I am requesting exemption from § 91.121 which details Altimeter settings. This regulation is inapplicable because the UAS makes use of electronic GPS for navigation and height settings.

I am requesting exemption from § 91.151(a) which covers Fuel Requirements for flight. My UAS is powered electronically, and will issue notifications for low battery status. The battery also keeps flight time under 10 minutes at one time and will land automatically if the battery has exhausted all of its

power.

How y our r equest would benefit t he publ ic a s a whole;

My r equest benefits t he p ublic a s a whole b y p roviding an o pportunity f or corporations, b usin ess

owners, agents of

r eal es tate and l aw , a nd any o ther i ndividuals who wish t o document t heir land o r property using the v ery u nique c apabilities the UAS provides, and a llows t hem t o do s o u sing an experie nced RC operato r that u n derstands how t o s afely fly such t echnology . This would allow these organizations with a means of providing otherwise unavailable visuals for their business , its clients and
other interests , thus increasing their marketing abilities and leading to growth of businesses and companies at an affordable cost. This will stimulate a safe and harmless economic growth in the community and its residents in which my business serves.Reasons why the exemption would not adversely affect safety, or how the exemption would provide

a level of safety at least equal to the existing rule;

Being an experienced RC UAS operator I would be a good candidate for exemption, and would not put Air Safety in any risk. The specific UAS (Phantom II Quadcopter) I am seeking exemption with is equipped with safety features, including GPS stability and navigation, as well as, real-time flight status and emergency LED beacons. When flying, I would generally be flying at a maximum altitude of 300ft in a very small and limited zone with slow movements, decreasing the risk of any interference. The UAS is battery powered and poses no risk to persons or the environment as it does not contain fuel or combustible liquids. My general knowledge of the FAA’s safety systems would be used to ensure that safety would not be affected by my operations. I would not be flying near any congested or disaster areas, sporting events, or high traffic areas including airports. The pre-flight checklist and maintenance procedures defined in the manual of this specific UAS (Phantom II Quadcopter) allow me to achieve a level of safety equivalent or higher to the existing rule.

Summary

I, Jo hn G uarino am s e eking a n exemption o f Sec 33 3 of th e FAA ’s rules th at does n ot allow th e us e of a n Unmanned A ircraft to b e u sed fo r C ommercial purposes in re gards t o N ational Airspace S afety. I am petitioning f or an exemption t o p rovide a commercial production service to p rivate lan d owners an d companies who w ish to o btain and capture a e rial photo and v ideo o f their proper ty f or p urposes including real estate endeavors, event d ocumentation

, an d fo r use as a marketing t ool for business . I am

an experience oper ato r and t echnician with s everal hours of flight e xperience in varying c onditions. I
would b e a go od c andidate f or exemption of S ec 3 33 and w ould not p ut ai r s afety at risk. The s pecific UAS ( Phantom I I Q uadcopter ) I a m s eeking exemption w ith is one w ith many s afety p rograms, including

GPS s tability an d n avigation, as w ell as, real -t ime flight s tatus an d e mergency LED b eacons

. W hen flying
for this c ommercial purpose

, I w ould g enerally b e flying at a maximum alt itude o f 150ft in a very s mall
and l imited z one with s low movements
, d ecreas ing t he ris k of any u nsafe flig ht. My general k nowledge

o f the F AA ’s safety systems would b e u sed to e nsure that s afety would not be affected b y my operations

. I w ould n ot b e fly ing n ear d isaster areas, s porting events, or high t raffic are as in cluding airports

. I ap preciate t he F AA’s c onsideration and t ime r eading this p etition f or e xemption.

Additionally, I h ave a 2 million dollar l iability insurance policy c ov ering commerc ial us e of t he UAS l isted i n this p etition. Thank

y ou agai n for

y our c onsideration.