June 1 2 , 2015

David Milkovich

30 Nelson Road Vestal, NY 13850

Cell 607

- 761

- 4977

Email: david.j.milkovich@gmail.com

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

– 2014

– 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC

Dear FAA,

In accordance with the FAA’s Guidelines for Su bmitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act
of 2012 , I, David Milkovich , request exemption from the following sections of Title 14, Code of Federal Regulations §§

91.119(c). 91.121. 91.151(a). 91.405(a).

91.4 07(a)(1). 91.409 (a)(1). 91.409(a)(2). 91.417(a) & (b).

This is i n order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, real estate ma rketing

, surveys and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the requestof and with the authorization and permission of clients or their authorized agents

in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted within
and und er the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by David
Milkovich are drawn from references 13.

The FARs

91. 119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The pet itioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. I, David Milkovich , request waiver for this condition to allow reasonable and responsible operations with safety as my main concern in areas of subdivisions and neighborhoods if required.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes
electronic GPS with a barometric sensor for altitude inf ormation.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 1 0673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, T he FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable.

91.405(a). 91.407(a)(1). 91.409 (a)(1) & (2). 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), I, David Milkovich

, propose to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner’s operating documents and the conditions and limitations specified,describing the requirements for mainten ance, inspection, and recordkeeping,

were sufficient to ensure that safety would not be adversely affected.

The UAS (s)

The Quanum Nova and Skywalker X8 are highly successful consumer grade
small UASs in the quadcopter and fixed

- wing configuration s. W ith an advertised weight of less than 36 ounces (1 00 2g) and designed primarily to carry aloft a high definition camera , the Quanum Nova has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/ s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm)

. With a fully configured weight of approximately 110 ounces and designed primarily to carry aloft a high definition camera, the Skywalker X8 has an esti mated maximum speed of less than 65 knots ( 33 m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by one electric motor

. Both aircraft u tilize an internal inertial measuring unit (IMU) with integrated barometric sensor aug mented with global positioning system (GPS) to maintain their geospatial orientation and position.
Both are controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground

con trol station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. Both ha ve fail safe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 2 0 minutes for both aircraft . The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is ant icipated that flights will usually last less than 15 minutes.

Risk mitigation
I, David Milkovich , have reviewed FAA exemptions reference’s 13 Conditions
and Limitations section and believe that the procedures specified therein are

reasonable and will be ut ilized in order to manage and mitigate risk and ensure public safety.

A preflight checklist will be developed and employed to ensure that the UAS’s airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine ins pections before each flight, maintaining flight and maintenance logs to record time on failure prone components.

I, David Milkovich , request that in a manner similar to reference 3, be allowed to operate within 5 miles of an airport provided that.“The UA may not operate in Class B, C, or D airspace without written

approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non

- towered airport as denoted on a current FAA published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request .”

Operations within 5 miles of an airport are not anticipated to be routine but I am requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel.

In regards to aerial photography, real estate marketing, surveys and other flight operations

, the UAS will minimize the risk to persons attempting to climb these structures and photograph problem areas. It will provide a way for companies to

have their staffs review photographs and provide additional safety to the general public in regards to identifying issues not visible from the ground such as chimney and roof inspections. T he UAS (s) can reach such structures to make a n assessment easier and safer.

I, David Milkovich , will also make the UAS and myself available to local volunteer organizations (for no charge) such as fire departments, local law enforcement, etc., to perform search and rescue operations, or other similar events as directed by authorities.

In addition the use of the UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for ch aracteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance my personal photography . A visual observer will be utilized at all times that the UAS is performing duties for compensation

.Flight data including UAS flight time, Control Unit operation time, incident, and

details will be recorded for each flight and made available to the FAA at any time
needed. Any deviations from normal operations will also be recorded and made

available to FAA.

Conclusion

I, David Milkovich am requesting this exemption for the purposes of aerial photography , real estate marketing, surveys and other flight operations , and other flight operations. The reason for such a general and broad based request is that I, David Milkovich

, intend to employ a business strategy in order to capitalize on opportunities as they may arise in the future without the long

turnaro und time associated with additional exemptions. My business model is based on the idea of offering small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or prevent structural failures that may influence the general public

or individuals. My own research shows an upward demand for these services that currently exists in the real estate market, natural gas market s, and other markets are just beginning to realize the ne ed for such services.

As an employee of Lockheed Martin Aviation & Unmanned Systems for 14 years, I am acutely aware of the responsibilities of safe Group 1 UAS operations. I
have flown Radio Controlled Aircraft for nearly 20 years . I am familiar with

ai rcraft preflight checks and procedures . I have approximately 250 total hours of flight between the two UAS(s) listed on this request.

Thank you for your consideration.

David Milkovich