United States Department of Transportation
Docket Management System
1200 New Jersey Ave., SE
West Building Ground Floor Room W12-140
Washington, DC 20590 

RE: Christopher Weekley with (D&I)'s Petition for Exemption to Operate Unmanned Aircraft Systems for Aerial Photography, Videography, and Photogrammetry

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. Part 11, Christopher Weekley (D&I) hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed herein and any other necessary to allow its operation of small Unmanned Aircraft Systems (UAS) to provide aerial photography, videography and photogrammetry services. The requested exemption would permit the operation of Blade 350 QX3 UAS to obtain aerial photographs and video for mapping, surveying, structural and roof inspections, and real estate sales.

BACKGROUND
Christopher Weekley co-founded of D&I Drone and Inspection Services in 2015 and began producing professional grade aerial photography. Mr. Weekley’s professional background includes education as an civil engineer and a Florida home and building inspector. He spent 12 years as an Active Duty Air Force member. He also built and flown radio control vehicles for the past 15+ years. In addition D&I co-founder Todd Cook spent 22+ years in the Air Force as a fire fighter and in contracting. D&I would like to expand operations and provide professional aerial photography, videography, and photogrammetry services to businesses and individuals in the Panama City area and surrounding counties of Washington, Walton, Okaloosa, Calhoun, Homes, and Gulf. The Unmanned Aircraft (UA) described herein is smaller, lighter and more maneuverable than conventional aircraft running on combustible fuel, operates at lower altitudes with no people on board and will thereby reduce current risk levels, enhance safety and diminish the likelihood of death or serious bodily injury. With a very small payload and maximum flight time of only 15 minutes, this offers little or no risk to national security. Additionally D&I requests to be allowed to use its system to benefit first responders nearby who may require assistance, including fire fighters, the police, the sheriff, and search and rescue, while remaining subject to all limitations cited herein as we do so.

THE UNMANNED AIRCRAFT (UA)
D&I has 2 Blade 350 QX3's.

Key Features
 •Wi-Fi Password: 1234567890
•Captures smooth, steady aerial video in brilliant high definition
•Includes everything in one box
•Easy to fly – no experience necessary
•10 - 15 minute flight times
•Mast-mounted GPS antenna for improved GPS performance
•5.8GHz Wi-Fi link for compatible iOS and Android devices
•Advanced SAFE® (Sensor Assisted Flight Envelope) technology
•Smart Flight Mode – SAFE CircleTM barrier, stick relative control response and GPS/Altitude hold
•AP Flight Mode – faster panning and tracking response with GPS/Altitude hold
•Return Home function – aircraft returns to start up point and lands on its own
•Blade® CGO2 GB 16MP 1080p/60 camera with integrated 3-axis brushless gimbal
•8GB Micro SD card included for camera
•E-flite® 3S 3000mAh 11.1V 30C Li-Po Flight Battery
•E-flite DC Li-Po battery charger with AC adapter
•SpektrumTM DX4 transmitter with mobile device mount
•Four AA transmitter batteries

Completion Level:   Ready-to-Fly  
 Rotor Type:   Quadcopter  
 Prop Diameter:   22.8 in (580mm)  
 Main Rotor Blade Length:   8.27 in (210mm)  
 Main Motor Type:   Brushless Outrunner  
 Battery:   E-Flite 3000mAh 3S 11.1V 30C LiPo, 12AWG, EC3  
 Length:   18.3 in (465mm)  
 Height:   7.48 in (190mm)  
 Width:   18.3 in (465mm)  
 Main Frame Material:   Plastic  
 Flying Weight:   33.7 oz (955g)  
 Approx Flying Duration:   15 minutes  


GROUND STATION EQUIPMENT
The ground station equipment is comprised of a dual control and audio communication 
equipment.
  Primary controller is for the Pilot in Command (PIC)
o  2.4 GHz radio control unit
o  5.8 GHz video receiver
o  Display of video and telemetry VIA Wi-Fi on Smart Phone

  Camera Controller operates the camera functions and does not affect aircraft control
o  Display of video and telemetry
o  Directional antenna for improved video reception.

  Radios for communications if needed to overcome distance or environmental noise.


GROUND CREW
  Pilot in Command (PIC). The pilot in command will have at least a private pilot 
license and a third class medical.
  Camera Operator (optional). The Camera operator controls the camera onboard the 
aircraft for photography and videography missions. For photogrammetry missions, 
the camera is in a fixed position and the camera operator is not necessary.
  Visual Observer (VO). The visual observer will provide additional situational 
awareness during flight operations.


OPERATIONAL PARAMETERS
1.  The UAS will weigh less than 55 pounds. (The Blade 350 QX3 weighs 34 oz.)
2.  Flights will be operated within visual line of sight of a pilot and observer.
3.  Maximum total flight time for each operational flight will be 15 minutes. Flights will be terminated at 20% battery power reserve should that occur prior to the 15 minute limit.
4.  Flights will be operated at an altitude of no more than 400 feet (122 meters) AGL. Unless a specific COA is obtained, the limit will be according to the “blanket” COA of 200 feet (61 meters).
5.  Minimum crew for each operation will consist of the UAS pilot and the Visual Observer.
6.  UAS pilot will have completed 4 hours of operator and safety training also have accumulated and logged at least 25 hours total flight time. Local AMA flying fields and rules will be used to accumulate flying time and practice emergency procedures. 
7.  Written permission will be obtained from the property owner.
8.  Pilot and observer will be able to communicate by voice at all times during the operation. Communication may be assisted by radio when necessary. Text 
communications are not allowed.
9.  The UAS will only be operated during daytime hours in VFR weather conditions.
10.  Operations may not be conducted aboard a moving device or vehicle.
11.  Operation near airports will be conducted according to the “blanket” COA unless another COA is obtained.
  5 nautical miles (NM) from an airport having an operational control tower; or
  3 NM from an airport with a published instrument flight procedure, but not an operational tower; or
  2 NM from an airport without a published instrument flight procedure or an operational tower; or
  2 NM from a heliport with a published instrument flight procedure
12.  Maximum speed 50 knots.


PRE-FLIGHT CHECKLIST
1.  Weather conditions are suitable for VFR flight and wind is 15 mph or less.
2.  Measure battery voltage to make sure batteries are fully charged before takeoff.
3.  Verify that all wiring connections are tight.
4.  Raise and lock all rotor arms. Inspect for cracks, damage, and loose hardware.
5.  Check to make sure propellers are secure and free from dirt, cracks and chips.
6.  Install main battery and check balance.
7.  Turn on camera equipment.
8.  Verify all switch positions on the RC transmitters. 
9.  Turn on radio control transmitters and video equipment.
10.  Connect the UAS main battery. Check for radio connection with RC transmitters and 
video downlink.
11.  During warm-up, check the Flight Controller LED indicator. A purple flashing LED indicates AP mode, and a happy tone means it is flight ready. 
12.  Announce your intention to take off by announcing “Take Off”.


DOCUMENTATION
The following documents are attached and provided to support this petition.
  Blade 350 QX3 User Manual


SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN EXEMPTION

A.  14 C.F.R. §§ 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command. 
These regulations limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers and be operated within limited areas and altitudes, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS.
B.  14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness
While the UAS will not have an airworthiness certificate in accordance with 14 C.F.R. part 21, Subpart H, the airworthy condition of the UAS will be the responsibility of the PIC in accordance with 14 C.F.R. § 91.7(b).
C.  14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas.
This regulation establishes safe altitudes for operation of civil aircraft over areas other than congested areas. BEAP requests relief from this section with respect to persons involved in the operation as well as vehicles and structures. The UAS will not be operated above 400 feet altitude. It will be operated in a defined area where people and buildings will not be exposed to operations without their pre-obtained consent.
D.  14 C.F.R. § 91.121 Altimeter Settings
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS does not have a barometric altimeter, an exemption is requested. The UAS Flight Controller utilizes GPS equipment aided by a static pressure sensor to determine and maintain altitude. The aircraft altitude above the takeoff point is provided in the video downlink telemetry information and provides sufficient information for the PIC to maintain altitudes at or below the 400 foot (122 meter) limitations.
E.  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 cursing 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.” Given that the UAS aircraft only fly for a maximum of 30 minutes and typically carry about 15 minutes of batter power, an exemption is requested. The UAS operations are always conducted within a few minutes of the takeoff and landing point and within a restricted area. D&I believes that terminating the flight with 20% remaining battery power provides an equivalent amount of safety that is intended by section 191.151(a).
F.  14 C.F.R. § 91.405(a) Maintenance Required; 14 C.F.R. § 91.407(a)(1) Operation after maintenance, preventative maintenance, rebuilding or alteration; 14 C.F.R. §§ 91.409(a)(1) and (2) Inspections; 14 C.F.R. §§ 91.417(a) and (b) Maintenance Records
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 have 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 the sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the Petitioner. Maintenance will be accomplished by the operator pursuant to the Owner’s Manuals. An equivalent level of safety will be achieved because these small UAS 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 UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initial 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. The FAA issued exemption to these regulations in Exemption No. 11062.


SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER

Petitioner: Christopher Weekley with D&I LLC 
Sections of 14 C.F.R Affected: §§ 61.113(a) and (b); § 91.7(a); § 91.119(c); § 91.121; § 91.151(a); § 91.405(a); § 91.407(a)(1); §§ 91.409(a)(1) and (2); §§ 91.417(a) and (b)

Description of Relief Sought: D&I LLC. seeks relief from the requirements of 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 
C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate small unmanned aircraft systems (UAS) for the purpose of aerial photography, videography, and photogrammetry.




Respectfully Submitted,
Christopher J Weekley

D&I Services LLC
4511 Hilltop Lane
Panama City FL, 32405
Phone: (850)357-7138
            (850)588-0073