Stephen W. Barrington

2914 Veterans Blvd SE Massillon, OH 44646 June 30, 2015
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91 .119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Stephen W. Barrington , operator of Small Unmanned aircraft Systems (“sUAS”), hereby applies for an exemption from the listed Federal Aviation Reg ulations (“FARs”) to allow commercial operation of its sUAS, so long as such operations are conducted within and under the conditions outlined herein or as my be established by the FAA as required by Section 333. This exemption request is made based on in formation outlined in this petition, as well as the accompanying aircraft manuals ( DJI Phantom 3 Professional http://www.dji.com/product/phantom

-3/download and DJI Inspire1 http://www.dji.com/product/inspire

- 1/download ). The DJI UAS product line was selected because they have a proven capability for controlled flight as well as a gyro stabilized flight mode, GPS aided navigation, a compass, blinking LED’s on the bottom, a failsafe mode for returning home, and prop guards. These devices are offered for general sale around the world and have often been used as Model Aircraft in the USA. In addition, I, Stephen W. Barrington , have flown UAS’s in a recreational capacity for several years and have adopted safety protocols and controls to avoid and prevent public hazard, as well as m anned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's specific to video and photography usage as I, Stephen W. Barrington , record flight data and other information gained through permitted flight opera tions to share with the FAA through any required FAA reports to assist with future protocol and safety regulation. Commercial operation sUAS, as described herein, which are equipped with cameras and sensors, would operate in the following manner:

1. Aerial p hotography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering. 3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.4. Aerial video/photography or providing live video feed to assist with search and resc ue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation. 5. The ability to offer training to persons individually or belonging to both private and/or public organizatio ns that have interests in the use and application of sUAS for the purpose of the safe operation of sUAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property. As described fully below, the re quested exemption would permit the operation of sUAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conve ntional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.” The name and address of the applicant is:
Attn: Stephen W. Barrington Ph: 330

-844

- 3596 Email: sbarrington114@yahoo.com Address: 2914 Veterans Blvd SE Massillon, OH 44646 Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CF R 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

My sUAS are multi

- rotor craft weighing no more than 55lbs. including payload. Under normal conditions they operate at speeds of no more than 50kts and have the ability hover and move along a vertical and horizontal plane simultaneously. They will operate in lin e of sight and will operate within a closed off and predetermined area owned and/operated by the property representative.Given the small size of the sUAS and the controlled environment provided the proposed operations will adhere to

the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emi ssions and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay. **AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY /CONDITIONS AND LIMITATIONS**  In this grant of exemption, Stephen W. Barrington is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exempt ion. 

### 1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 Professional and DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 

### 2. Operations for the purpose of closed

-set motion picture and television filming are permitted. 

### 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed o r calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 

### 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 

### 5. The UA must be operated 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, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license. 

### 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual lin e of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 

### 7. This exemption an d all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible du ring UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions forextension or amendment to this grant of exemption. If the operator determine s that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 

### 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight p rior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not p ose an undue hazard to persons and property. 

### 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 

### 10. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine t he UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircra ft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 

### 11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 

### 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

### 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

### 14. Th e operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropri ate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from no nparticipants in accordance with 14 CFR § 91.119. 

### 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 

### 16. The UA may not operate with in 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of theairport symbol as denoted on the current FAApublished aeronautical chart, unle ss a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement offic ial upon request. 

### 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

### 18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled

-access property. 

### 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

### 20. The PIC is prohibited from beginning a flight unless (considering wind and forec ast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 

### 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 

### 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber ) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

### 23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be avail able to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 

### 24. The UA must remain clear and give way to all manned av iation operations and activities at all times. 

### 25. The UAS may not be operated by the PIC from any moving device or vehicle. 

### 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: 

### a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must 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 UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and 

### b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential p ersons are not considered nonparticipating persons under this exemption.

### 27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 

### 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

-set motion picture and television filming and production, the following additional conditions and limitations apply. 

### 29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption. 

### 30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction o ver the area of proposed filming. The 3

-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following: 

### a. Dates and times for all flights; 

### b. Name and phone number of the operator for the UAS aeria l filming conducted under this grant of exemption; 

### c. Name and phone number of the person responsible for the on

-scene operation of the UAS; 

### d. Make, model, and serial or N

- Number of UAS to be used; 

### e. Name and certificate number of UAS PICs involved in the aeri al filming; 

### f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; 

### g. Signature of exemption holder or representative; and 

### h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 

### 31. Fligh t operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

**14 C.F.R. Part 21, Subpart H: Airworthiness Certi ficates 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 associa ted with the aircraft to be utilized by the Applicant, 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 Section 3 33 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 sUAS. In all cases, an analysis of these criteria

demonstrates that the sUAS 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 (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated hereunder is less than 55 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 complianc e with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificat es 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 sUAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry 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 displaye d 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 sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to t he cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification of the sUAS as “Experimental.” **14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command.**  Pursuant to 14 CFR 61.113 (a), 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. Our sUAS do not carry any pilots or passengers nor property therefore I am seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot’s license will not ensure remote control piloting skills. The risks attendant to the operation of sUAS is far less than the ris k levels inherent in the commercial activities outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will equate to the safe operation of the sUAS. **14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.** The regulation requires tha t 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 determining airworthiness. Give n the size of the aircraft for maintenance and use of safety check lists 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) provides: No pers on 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 Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, 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 the pilot flying the sUAS will have immediate access to it.
**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 will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. **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. sUAS and remotely piloted aircraft, by their design do not have fully functional dual contro ls. 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 fl ight instruction in experimental aircraft. The equivalent level of safety provided by the 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.**
Se ction 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 sUAS 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 filming is planned, an exemption may be needed to allow such operations. As set forth herein, the sUAS will never operate at higher than 400 AGL with the exception that in circumstances where the sUAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the sUAS will n ot be operated more than 100' 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 pre

-obtained consent. The equival ent level of safety will be achieved given the size, weight, speed of the sUAS 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 prope rty 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 sUAS will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must 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 reference to an altimet er that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an 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 point 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 battery powering the sUAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a l onger time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the small UAS, in a tightly controlled area where only p eople and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the s mall UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power — whichever happens first. This restriction would be more than adequate to return the sUAS 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 paragraph (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 passenge rs or crew. The sUAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS.**14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Ma intenance Inspections.** 

These regulations require that an aircraft operator 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, h ave 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 section and Part 43 apply only to aircraft with an airworthiness certificate, these se ctions will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the sUAS is in working order pri or to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator 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 will be achieved because maintenance and inspections will be performed in accordance with the sUAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the operator will ensure that the sUAS is in working order prior to initiating flight and perform required maintenance needed. **In summary, Stephen W. Barrington**  **seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H**  **; 14**  **C.F.R. 45.23(b**  **) ;**  **14 C.F.R.**  **§§ 61.113**  **(a) &**  **(b); 14**  **C.F.R. §**  **91.7 (a);**  **14 C.F.R.**  **§ 91.9**  **(b)(2); 14**  **C.F.R. §**  **91.103(b) ;**  **14 C.F.R.**  **§ 91.109;**  **14 C.F.R.**  **§ 91.119;**  **14 C.F.R.**  **§ 91.121;**  **14 C.F.R.**  **§ 91.151(a);**  **14 C.F.R.**  **§§ 91.203(a)**  **and (b)** **; 14**  **C.F.R. §**  **91.405 (a);**  **14 C.F.R.**  **§ 9**  **1.407 (a)(1)** **; 14**  **C.F.R. §**  **91.409 (a)(2);**  **14 C.F.R.**  **§ 91.409**  **(a )**  **(2) ;**  **and, 14**  **C.F.R. §§**  **91.417 (a)**  **& (b)**  **to commercially**  **operate my**  **lightweight unmanned**  **aircraft system**  **for aerial**  **photography/Inspection/ and**  **other related**  **professional activities,**  **included but**  **not limited**  **to the**  **following ;**  **Business Operations:**  **over land,**  **water ways,**  **and oceans** **; operation**  **over/in non**  **restricted National**  **Parks, National**  **Forests, flight**  **in non**  **navigable airspace,**  **using non**  **intrusive recording**  **devices, operation**  **in otherwise**  **unr estricted**  **U.S. States/Territories**  **for aerial**  **videography/cinematography for**  **commercial operation**  **and to**  **enhance academic**  **community awareness**  **for those**  **individuals and**  **companies unfamiliar**  **with the**  **geographical layout**  **of such**  **areas. Currently,**  **area awarenes** **s and**  **real estate**  **aerial videography/photography**  **relies primarily**  **on the**  **use of**  **larger aircraft**  **running on**  **combustible fuel,**  **posing potential**  **risk to**  **the public.**  **Granting my**  **request for**  **exemption will**  **reduce current**  **risk levels**  **and thereby**  **enhance safety.**  **My UAS**  **does not**  **contain potentially**  **explosive fuel,**  **is smaller,**  **lighter and**  **more maneuverable**  **than conventional**  **photographic aircraft**  **with much**  **less flight**  **time. Further,**  **I operate**  **at lower**  **altitudes and**  **in controlled**  **airspace eliminating**  **potential public**  **risk flying**  **to and**  **from established**  **airfields. I**  **have been**  **analyzing flight**  **information and**  **will compile**  **safety protocols**  **and the**  **implementation of**  **a flight**  **operations manual**  **that exceeds**  **currently accepted**  **means and**  **methods for**  **safe flight.**  **Formal collect**  **ion of**  **information shared**  **with the**  **FAA will**  **enhance the**  **FAA's internal**  **efforts to**  **establish protocols**  **for complying**  **with the FAA Modernization and Reform Act of 2012. There are no personnel on board my UAS and therefore the likelihood of death or serious b** **odily injury**  **is significantly**  **diminished. The**  **operation of my UAS,**  **weighing less**  **than 7**  **pounds and**  **travelling at**  **lower speeds**  **within limited**  **areas will**  **provide an**  **equivalent level**  **of safety**  **as that**  **achieved under**  **current FARs.**  **Accordingly I**  **respectfully re** **quest that**  **the FAA**  **grant my**  **exemption request**  **and am**  **willing to**  **cooperate in**  **sharing information**  **to benefit**  **the FAA,**  **safety of**  **manned aircraft, and the general public at**  **large. Due**  **to file**  **size uploading**  **restrictions, the**  **official DJI**  **Phantom 3**  **manuals ca**  **n be**  **found at** 

**http://www.dji.com/product/phantom**
**- 3/download**  **and DJI**  **Inspire 1**  **manuals can**  **be found**  **at http://www.dji.com/product/ins**  **pire -**  **1/download .**  Very Respectfully, Stephen W. Barrington

2914 Veterans Blvd SE Massillon, OH 44646 Sbarrington114@yahoo.com