Petition for Exemption From Section 333 of CFR 14

Information for ​§11.81

(a) Mailing Address​: George Belanger, 19 Montgomery Ave, Caribou, Maine 04736.

Cell Phone Number​: 207 7680712

Email Address: ​george.m.belanger@maine.edu

(b) ​The petitioner, herein known as Dronographs, is applying for exemption from Section 333 of

14 C.F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R.

§91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14

C.F.R. §91.409(a) 14 C.F.R. §91.417(a)&(b) Description of Relief Sought: Petitioner seeks relief

from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 61.113(a)&(b)), 91.119(c),

91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to conduct sUAS operations

over Dronographs Client’s owned or controlled land, solely during daylight hours, to assist in the

safe evaluation and analysis of infrastructure and operations as well as capture two and three

dimensional images primarily in rural real estate.

(c) ​Petitioner Dronographs reasons for exemption from: Section 333 of CFR 14. 14 C.F.R.

91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) §91.405

Maintenance required. Each owner or operator of an aircraft – (a) 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, have discrepancies repaired as prescribed in part

43 of this chapter; ***** §91.407 Operation after maintenance, preventive maintenance,

rebuilding, or alteration. (a) No person may operate any aircraft that has undergone

maintenance, rebuilding, or alteration unless – (1) It has been approved for return to service by

a person authorized under §43.7 of this chapter; ***** §91.409 Inspections. (a) Except as

provided in paragraph (c) of this section, no person may operate an aircraft unless, within the

preceding 12 calendar months, it has had (1) An annual inspection in accordance with part 43 of

this chapter and has been approved for return to service by a person authorized by §43.7 of this

chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with

part 21 of this chapter. ***** §91.417 (a) & (b) ***** Dronographs believes that an exemption

from these three maintenance requirements is appropriate because the FAA has not developed

maintenance standards that would allow an operator to meet the part 91 maintenance

requirements. In particular, there are no individuals authorized by the FAA to approve a sUAS

for return to service under §91.407(a) or to conduct the initial airworthiness and annual return to

service inspections required by §91.409(a). Dronographs will maintain the aircraft as instructed

in the user manual(s) and ASTM F2909, where applicable, and will not operate the aircraft until

it has reasonably determined that any needed repairs have been made. However, because of
the technical impossibility of meeting the requirements of §§91.405(a), 407(a), 409(a) and

417(a)&(b), we believe an exemption from these provisions is appropriate. Please do not

hesitate to contact me at the phone number or via the e­mail address provided above should

you have any questions or concerns. Appendix A Summary for Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register should the FAA determine that publication is needed.

(d) ​In general, sUAS operations are intended to be conducted in areas remote from both

congested areas and airports. The nature of operations anticipated by Dronographs requires

that the sUAS be flown at relatively low altitudes. Dronographs expects that in most instances,

the sUAS will be flown less than 75 feet from the highest structure along the path of the sUAS

and in no instances will be flown higher than 200 feet above the ground. Dronographs will also

not fly within 200 feet of property, structures or individuals uninvolved with our flight subject. Bill

Belanger will serve as PIC and George Belanger as visual observer, with both individuals

keeping VLOS at all times. Dronographs’ PIC Bill Belanger possesses airman certificate level

ATP: Airline Transport Pilot. The PIC has been screened by TSA and meets all medical

standards. He has 6,000 hours total flight time and 40 recreational daytime flight hours with the

phantom 2, with a minimum of 20 hours recreational flight time with 3DR Solo before utilizing it

in commercial applications.

The 3DR Solo and DJI Phantom 2 user manuals are attached below to provide characteristics

such as design, size, weight, speed, operational capability, operating procedures, aircraft

loading information and radio frequencies of UAS in as much detail as possible. A flight routine

starts by checking that we’re at least 5 nautical miles away from an major or minor airports. Next

we check that we have written permission by the owner if flying on private property, per Maine

state law. Next a check for weather and time of day. Next a hazard check of any property line,

structure or individuals to avoid by 200 feet. Next a check that the voltage of lithium ion batteries

in aircraft and controller are above 90%. Next a check that the prop blades are properly

fastened and the aircraft is structurally sound. Next a power on to test GPS satellite signal, a

test of rotors and a test of 5.8 GHz transmission. Finally a one minute, close to ground flight

check to make sure all systems function properly before carrying out the task at hand.

The pilot will operate the PHANTOM 2 and 3DR Solo in safe environments that are strictly

controlled, away from power lines, lights, airports and populated areas. The pilot will establish

takeoff and landing zones by a space no smaller than ten (10) feet by ten (10) feet, and clear of

overhead and lateral obstructions. The PIC will also check the area to determine if there are

any potential radio frequencies or electrical transmissions that could interfere with the safe

operation of the aircraft. Maximum total flight time for each operational flight will be 20 minutes.

Flights will be terminated at 30% battery power reserve should that occur prior to the 20-minute

limit. Additionally, a minimum of one reserve battery will be kept fully charged and available at

all times. If the sUAS loses communications or loses its GPS signal, it will return to a
pre-determined location within the planned operating area or be recovered. The PHANTOM 2

and 3DR Solo will be operated under normal conditions, only during daylight hours, at speeds of

5 to 30 knots. The radius distance from the controller to the sUAS will not exceed 1,000 feet.

The sUAS will remain clear and yield the right of way to all other manned aviation operations

and activities at all times.

(e) ​Accordingly, the risk of interference with other aircraft in NAS is minimal. Considering the

information on public safety hazards and risks Dronographs will produce, the public, to their

benefit, will become more safe and knowledgeable if Dronographs is granted an exemption. It

will fill an emerging need in rural and central Maine for the provision of 2D and 3D aerial

imaging services that provide businesses and professionals with realistic visualizations of both

past and projected scenes. For example, it will provide numerous industries with new and

innovative ways to visualize their property development projects ­­ whether it’s for real estate,

construction projects, or historical preservations. All proposed aerial imaging operations would

be conducted by Dronographs under controlled conditions in airspace that is: 1) limited, 2)

predetermined, and 3) access controlled.

(f) Federal Register Summary​: Exemption from section 333; Aerial photograhy and

videography.

(h) Dronographs does not wish to exercise a section 333 exemption outside of the United

States of America.