Pronalysis

Attn: Paul Campbell 2702 Big Branch Road Viper, KY 41774

Hon. Michael Huerta Administrator Federal Aviation Administration U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from certain parts ofthe FARs. Dear Administrator Huerta: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Pronalysis hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow it to operate a small Unmanned Aircraft System (“sUAS”) under the conditions and limitations set forth in this Petition. The requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that (1) is limited, (2) is predetermined, and (3) would provide safety enhancements to First Responders on the front lines in our communities. Approval ofthis exemption would thereby enhance safety and fulfill the FAA Administrator’s responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) ofthe Reform Act.
The name and address ofthe applicant is: Pronalysis Attn: Paul Campbell Telephone: (606)233
-2916 Email: orteaga2k2@gmail.com Address: 2702 Big Branch Road, Viper, KY41774Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. § 45.23(b) 14 CFR § 61.3 14 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2) 14 C.F.R. § 91.103 14 C.F.R. § 91.109 14 C.F. R. § 91.119 14 C.F.R. § 91.121 14 CFR § 91.151 (a) 14 CFR § 91.203 (a) & (b) 14 CFR § 91.205(b) 14 CFR § 91.215 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2) 14 CFR § 417 (a) & (b) 3 Appendix 1 describes the FARs from which an exemption is requested and summarizes the justification for each requested exemption. The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) ofthe Reform Act, which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Administrator must determine which types of UASs do not create a hazard to users ofthe NAS or the public or pose a threat to national security in light ofthe following:

• The UAS’s size, weight, speed, and operational capability;
• Operation ofthe UAS in close proximity to airports and populated areas; and
• Operation ofthe UAS within visual line of sight ofthe operator. Reform Act § 333 (a). Ifthe Administrator determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333(c). The Secretary has delegated his aviation authority to the Administrator ofthe FAA. The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory requirements for civil aircraft, a term defined under §40101 ofthe Act, which includes sUASs. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702
---44716 of the Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1).The Petitioner is a startup company, Pronalysis
. The founder ofthe company is a certified Police Officer
.

As a law enforcement official, he understands the importance of public safety
. He is keenly aware ofthe importance for safety in all facets of operating a sUAS in the national airspace. The Petitioner has formulated a business plan to provide photo and videography services to real estate agencies, media outlets, private companies, attorneys, insurance companies and local,state and federal entities. Under the plan, the unmanned aircraft (UA) used will be a DJI Phantom 3 Professional flying below 400 feet above ground level and never within 5 miles of an airport with an operating control tower. Operations will be conducted by a team including the pilot in command (PIC) and a visual observer (VO) and will only operate within the unaided, visual line of sight ofthe PIC and VO. Flights will be only conducted during daylight hours under VFR conditions and will not exceed limitations put in place by the manufacturer. Priortooperatingthe UA, all pre---flight checkswill beconducted as perthe manufacturer’s recommendations. Safety will be the paramount concern in defining flight profiles. Petitioner has read the congressional mandate in sections 332 and 333 ofthe FAA Revitalization and Reform Act of 2012 that the FAA move quickly to accommodate the economic andsocietal benefits that can result from widespread deployment of sUAS technology. Accordingly, Petitioner applies for authorization under the Federal Aviation Act and the FARs to undertake thefollowing activities for commercial purposes. Unless the Petition is granted, Petitioner will be at asignificant competitive disadvantage if it, as it prefers, complies with FAA policy. **Vehicle** The Petitionerwillflyone DJI Phantom 3 Professional equippedwith athree

---axis gimbal and camera. This vehicle has the built in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator, and to exclude them from class B, C, and D airspace as well as any Temporary Flight Restricted areas.Thevehicle also hasthe built

---in capabilityto return tothe launching point ifthe wireless control link is interrupted or ifthe operator attempts to exceed anyof the height, radius, or airspace limitations programmed into it.
The vehicle weighs approximately four pounds and has a maximum gross weight of approximately six pounds. It hasa topspeed ofapproximately32 mph. It hasfourfixed

---pitch rotors,thrustfrom which is varied bychanging RPM. It is powered by a lithium polymer smart battery.**Flight profiles** 

The petitioner will program the Phantom so that it will not fly more than 400 feet above ground level, or more than 1500 feet away from its operator. The PIC will carefully conduct a preflight inspection on the UA before each mission to assure that its compass and GPS system are properly calibrated and thatthe return---to---homefeature,altitude,andradiuslimitationswork. It will not operate in controlled airspace. In the unlikely event that a manned aircraft flies below 400 feet AGL where the Petitioner is operating its Phantom, the operator will keep both the vehicle and manned aircraft in sight and avoid the manned aircraft. **Public interest**  Granting the petition would be in the public interest because: 1. The Congress ofthe United States has determined that early accommodation of sUAS into the National Airspace System advances the public interest. The Committee Report leading the House to adopt H.R. 658 said: "The successful integration of unmanned aircraft systems (UAS) into the National Airspace System (NAS) can support morethan 23,000 high

---payingjobs inthe United States.
. . .The absence ofa planto integrate UASs into the NAS is a barrier to such job creation
. . . ."1 Granting the Petition represents a step toward such integration, in the absence of a comprehensive regulatory regime for sUAS, and thus would serve the Congressional goal and the public interest. 2. Granting the Petition will enable Petitioner to demonstrate the commercial viability of creating new safety techniques and tactics with new aeronautical technology, thereby improving the efficiency of Emergency Responders around the world and making for a safer society. The rules from which Petitioner seeks exemption artificially and irrationally limit the effective use of new technologies to expand Emergency Response safety and improve the efficiency of markets, thereby subverting the public interest. 3.Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation technologies advances the public interest. The FAA itself has recognized the public interest in its role of "Encouraging and developing civil aeronautics, including new aviation technology."2 Granting the Petition will enhance FAA fulfillment ofthat commitment, thereby serving the public interest. Air commerce flourishes in the United States because ofthe rapid pace of innovation in aeronautical and associated technologies, followed by their commercialization and their introduction into the marketplace. The UA technology that the Petitioner uses exemplifies the latest innovative leap forward in aeronautical technology. Preventing it from using this in air commerce subverts achievement ofthe goal.

1. H. R. Rep. 112
---29on H.R.658, 112thCong., 1stSess.at116.The House
---SenateConferenceCommitteeonthe FAAModernizationand Reform Actof2012 recommendedamendmentstoH.R.658in lieuofamendmentsadopted bytheSenate.Conference ReporttoAccompany H.R. 658,H.R.Rep.112
---381,112thCong.,2dSess.,atp.1(Feb.1,2012).4. Granting the Petition will fulfill the Congressional determination that integrating sUAS technology into

the NAS serves the public interest. Section 330 ofthe FAA Modernization and Reform Act of 2012, specifically recognizes the advantages to air commerce obtainable from the deployment of sUAS technologies. It mandated several steps by the FAA to accelerate the availability ofthese technologies in the National Airspace System, thereby representing a congressional determination that the public interest is served by making these technologies more widely available at the earliest practicable date. The Petition represents a way for the FAA to move incrementally, while still satisfying its congressional mandate and meeting its obligation to enhance the public interest by making new technologies available by allowing the use of sUAS technologies in a manner that protects the public and the rest ofthe aviation community from significant risk. The commercial activities by Petitioner proposed in the Petition represent contributions to new forms of air commerce, thereby fulfilling the FAA’s statutory mandate under the 2012 Act. 5. Granting the Petition will enhance aviation safety, thereby advancing the public interest. The Petitioner has committed itself in the Petition to safety practices that reduce or eliminate hazards to aircraft in the National Airspace System and to persons and property on the ground. Many others are flying sUAS without regard to these hazards. Granting the Petition will offer the Petitioner up as an example of how the FAA is willing to accommodate the new technology when it is constrained by appropriate limitations to enhance safety. It will also allow the Petitioner to be a role model for safe commercial sUAS operations. Users of the National Airspace System are confronted by mushrooming threats from sUAS flown in defiance ofthe FAA’s ban. Unless the FAA shows some flexibility to accommodate lawful and safe operation of sUAS for legitimate commercial purposes, the level of defiance will increase, intensifying the hazards to manned aircraft and to persons and property on the ground. The Petitioner's proposed operations satisfy the criteria provided in Section 333 ofthe Reform Act relating to size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight, and national security. The Petition justifies grant ofthe requested exemptions to allow the Petitioner to engage in civil operation using a sUAS. Respectfully Submitted, Paul Campbell Pronalysis**FAR section**  **Subject Justification** 

**14 CFR**  **§ 45.23(b)**  **Requirement to**  **display registration**  **number on**  **vehicle Insufficient**  **space on**  **vehicle**
**14 CFR**  **Part 21**  **Aircraft certification**  **requirements and**  **procedures Designed**  **for manned**  **aircraft; not** **suitable for** **off -** **- -the** **- -** **-shelf sUAS**  **14 CFR**  **§ 61.3**  **Requirement for**  **pilot certificate**  **Part 61**  **requirements designed**  **for manned**  **aircraft, not**  **sUAS; petition**  **describes training**  **for sUAS**  **operator 14**  **CFR §**  **91.7 (a)**  **Airworthiness requirement**  **Designed for**  **manned aircraft;**  **not suitable** **for off** **- -** **-the -** **- -shelf**  **sUAS 14**  **CFR §**  **91.9 (b)**  **(2) Requirement**  **for manual**  **to be**  **available in**  **the cockpit**  **No one**  **aboard to**  **read manual** 
**14 CFR**  **§ 91.103(b)**  **Requirement for**  **crew members**  **to be**  **onboard Un** **m anned**  **veh i** **c l** **e 14**  **CFR §**  **91.109 Requirement**  **for dual**  **controls during**  **flight instruction**  **No one**  **aboard to**  **operate controls**  **14 CFR**  **§ 91.119**  **Minimum altitudes**  **for safe**  **flight Safety**  **requires operation**  **below these**  **altitudes 14**  **CFR §**  **91.121 Altimeter**  **settings No**  **one aboard**  **to read**  **altimeter 14**  **CFR §**  **91.151(a) Fuel**  **requirements Vehicle**  **does not**  **use fuel**  **14 CFR**  **§ 91.203**  **(a) &**  **(b) Requirement**  **for registration**  **and airworthiness**  **certificates to**  **be onboard**  **No one**  **aboard to**  **read certificates** 
**14 CFR**  **§ 91.205(b)**  **Cockpit instruments**  **No one**  **aboard to**  **read FAR**  **section Subject**  **Justification 14**  **CFR §**  **45.23(b) Requirement**  **to display**  **registration number**  **on vehicle**  **Insufficient space**  **on vehicle** 
**14 CFR**  **Part 21**  **Aircraft certification**  **requirements and**  **procedures Designed**  **for manned**  **aircraft; not** **suitable for** **off -** **- -the** **- -** **-shelf sUAS**  **14 CFR**  **§ 61.3**  **Requirement for**  **pilot certificate**  **Part 61**  **requirements designed**  **for manned**  **aircraft, not**  **sUAS; petition**  **describes training**  **for sUAS**  **operator 14**  **CFR §**  **91.7 (a)**  **Airworthiness requirement**  **Designed for**  **manned aircraft;**  **not suitable** **for off** **- -** **-the -** **- -shelf**  **sUAS 14**  **CFR §**  **91.9 (b)**  **(2) Requirement**  **for manual**  **to be**  **available in**  **the cockpit**  **No one**  **aboard to**  **read manual** 
**14 CFR**  **§ 91.103(b)**  **Requirement for**  **crew members**  **to be**  **onboard Unmanned**  **vehicle 14**  **CFR §**  **91.109 Requirement**  **for dual**  **controls during**  **flight instruction**  **No one**  **aboard to**  **operate controls**  **14 CFR**  **§ 91.119**  **Minimum altitudes**  **for safe**  **flight Safety**  **requires operation**  **below these**  **altitudes 14**  **CFR §**  **91.121 Altimeter**  **settings No**  **one aboard**  **to read**  **altimeter 14**  **CFR §**  **91.151(a) Fuel**  **requirements Vehicle**  **does not**  **use fuel**  **14 CFR**  **§ 91.203**  **(a) &**  **(b) Requirement**  **for registration**  **and airworthiness**  **certificates to**  **be onboard**  **No one**  **aboard to**  **read certificates** 
**14 CFR**  **§ 91.205(b)**  **Cockpit instruments**  **No one**  **aboard to**  **read**