January 11, 2015

David Rabold 113 Alpine Court Bowling Green, KY USA 42104 Mobile: (270) 303

-9741 Home: (270) 842

- 1893 Email: david.rabold@crye

- leike.com
Federal Aviation Administration: I , David E. Rabold , am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F .R. 11, to request that I , David E. Rabold , owner and operator of small unmanned aircraft (DJI Phantom 3 Professional) and registrati on number FA3WCX44MH , be exempted from the Federal Aviation Regulations ("FARs") listed below so that I , David E Rabold , may operate a small ultralight unmanned aircraft system (''UAS") commercially to be used for remote sensing to support aerial data coll ection specifically photography and video capture of residential and commercial properties including golf courses in airspace regulated by the Federal Aviation Administration ("FAA") in accordance with FAA UAS Regulations & Policies. I would like to forma lly submit for an exemption from the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(l), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(l), 14 C.F.R. 91.409(a)(l) and (2), 14 C.F.R. 91.417(a) and (b) to operate a Phantom 3 Professional . This proposed exemption would allow the operation of unmanned aircraft systems (UAS) for the purpose of a erial videography/ photography as a service to the public/ business interests. As found in exemption No. 14078, No. 14097, and No. 14099. The Phantom 3 Professional was selected because it has proven reliable flying capabilities and upgraded vision positi oning system VPS, GPS aided navigation, blinking LEDs, failsafe mode for returning home when battery reaches a predetermined l o w warning, and prop guards. Also , records all take offs, landings and flight paths. The following are the DJI Phantom 3 Profes sional unmanned aircraft (UA) specifications: 1. Take

- Off Weight 1280g 2. Max Ascent Speed 5m/s 3. Max Descent Speed 3 m/s 4. Hover Accuracy Vertical: +/

-0.1m (when Vision Positioning is active) Horizontal: +/

- 1.5m 5. Max Speed 16 m/s (ATTI mode, no wind) 6. Max Flight Ti me Approximately 23 minutes 7. Battery Type LiPo4S 8. Remote Controller Operating Frequency 2.400 GHz

- 2.483GHz9. Remote Controller Max Distance up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC complainant and up to 3.5 km or 2.1 miles (unobstr ucted, free of interference) when CE compliant 10. Remote Controller Operating temperature 0 degrees C

-40 degrees C 11. Remote Controller Battery 6000mAh LiPo 2S



## Petitioner’s Previous Credentials FAA Commercial Pilot Certificate, ratings: Airplane Single/Multiengine Land, Instrument Airplane, Flight Instructor Kentucky Driver’s License Class D License #R94

- 138

- 791 expiration 02/19/2019 

## Specific section or sections of 14 CFR which I seek relief and the reason I seek relief: 14 C.F.R. Part 21: Airworthine ss Certificates Given the size and limited operating area associated with the aircrafts to be utilized by David E. Rabold , an exemption from Part 21 meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the reform Act. I n all cases, an analysis of these criteria demonstrates that the UA operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than conventional aircraft operating with an airworthiness certificate without restrictions and conditions proposed. 14 C.F.R. 45.23: Display of marks: general The UA does not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain words or phrases. Further, the two inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Small markings have been affixed to aircraft (drone) regarding aircraft registration number FA3WCX44MH. 14 C.F.R. 61.113 (a) & ( b): Private pilot privileges and limitations: Pilot in command The FAA has previously declared that additional manned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operat ions in previously issued exemptions to this regulation through Exemption Nos. 11062 and 11138. 14 C.F.R 91. 7: Civil aircraft airworthiness Currently, since there is no certificate applicable to the UAs in question, this regulation is inapplicable. 14 C.F.R. 91. 9 (b) (2): Civil aircraft flight manual, marking, and placard requirementsRequires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this

aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the operator. 14 C.F.R. 91.119(c): Minimum safe altitudes I , David E. Rabold , will ensure that UAS do not operate any higher than 400 feet at ground level. I will not fly over congested areas. I will plan operations before hand, for proper flight safety, and proper height analysis as to avoid collisions. 14 C.F.R. 91.121: Altimeter settings The UAS utilize electronic GPS and a light bridge sensor. An equivalent level of safety will be achieved by using this. 14 C.F.R. 91.151(a) (l): Fuel Requirements for flight in VFR conditions The UAS that we will fly are powered by electricity, using LiPo 4S battery that currently have a flight limit of approximately no more t han 2 3 minutes. Therefore, due to the limitations of the battery, it is currently impossible to comply with part 91.151. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required Currently, there are no procedures for providing airworthiness c ertificates for the mentioned UAS. I , David E. Rabold , however will always fly safely while having the manual of the DJI Phantom 3 Professional on hand. C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a) (l): Operation after maintenance, preven tive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a) (I) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworth iness certificate. However I , David E, Rabold , will perform preflight inspections of the UAS before each flight as outlined in the operating documents. I , David E. Rabold, will also follow manufacturer recommendations from said operating documents. 

## Public Interest Aerial photography and videography as an available service to the public allows for a cheaper method to capturing imagery than its alternative. Its alternative being aircraft and helicopters. They are expensive, create lots of noise, and a re much more threatening due to size and combustible fuel. I , David E. Rabold , would gladly offer my services upon request and with proper coordination to any official search and rescue or emergency services organization to benefit the public. Also as me ntioned in the Trudeau exemption, exemption No.11138: ""Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons or more of fue l. The petitioner's [UAS] weighs less than 3 lbs. The pilot and crew will be remotely locatedfrom the aircraft. The limited weight reduces the potential for harm to persons or damage to property in

the event of an incident or accident. The risk of an onbo ard pilot and crew during an incident or accident is eliminated with the use of a [UAS] for the proposed operation." 

## Summary I , David E. Rabold , am seeking exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 1 4 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(l), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(l), 14 C.F.R. 91.409(a)(l) and (2), 14 C.F.R. 91.417(a) and (b) With the exemptio ns of the mentioned rules I , David E. Rabold , will be seeking to make my drone photography/videography services available to my clients and the public. By not using combustible fuel, flying at safe heights and strictly following the usage recommendations from DJI Phantom 3 Professional

. These include but are not limited to:

 Flying the following UAS Safely
 DJI Phantom 3 Registration Number FA3WCX44MH
 Flying below 400 feet
 Proper visual inspection of UAS before flights
 Keeping mentioned UAS in visual sight at all times when in operation
 Using an observer to assist if needed
 Remain well clear of and do not interfere with manned aircraft operations, and avoid other aircraft and obstacles at all times
 Not intentionally fly over unprotected persons or moving ve hicles
 Contact the airport or control tower before flying within 5 miles of an airport
 Not flying in adverse weather conditions such as high winds or reduced visibility
 Not flying under the influence of alcohol or drugs
 Ensure the operating environment is safe
 Not flying over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, etc.
 Check and follow all local laws and ordinances before flying over private property
 Do not conduct surveillance or ph otograph persons in areas where there is an expectation of privacy without the individual's permission. Respectfully, David E. Rabold 113 Alpine Court B owling Green, KY 42104 USA Mobile: (270 ) 303

-9741 Home: (270) 842

- 1893 Email: david.rabold@crye

- leike.com