January 11, 2016 Adam Deets 1311 E 16th Cir La Center, Washington 98629 630-640-4424

U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113(a) & (b); 91. 7(a); 91.103 ; 91 . 119(c); 91 . 121; 91.151(a); 91.405{a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b). Dear Sir of Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14C.F.R. Part 11 , Adam Deets, licensed airplane and rotorcraft pilot of 18 years and an operator of Unmanned Aircraft Systems ("UAS") equipped to conduct aerial photography and videography, real estate photography, aerial surveying and mapping, windmill inspections, cell tower inspections, powerline and pipeline inspection and patrolling , wildlife and forestry monitoring, search operations, construction inspection , general infrastructure, and precision agriculture, hereby applies for an exemption from the Federal Aviation Regulations ("FARs") to allow commercial operation of its UASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As described below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive UASs under controlled conditions. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's {the FAA Administrator's) responsibilities to "...establish requirements for the safe operation of such aircraft systems in the national airspace system ." Section 333(c) of the Reform Act.The name and address of the applicant is: Name: Email: Address: Phone: Adam Deets adeetsUAS@gmail.com 1311 E 16th Cir. La Center, 

### WA 98629 630-640-4424 Regulations from which the exemption is requested:

• 61.113(a)&{b) • 91 .7(a) • 91.103 • 91.119(c) • 91.121 • 91.151(a) • 91.203(a) & (b) • 91 .405(a) • 91.407(a)(1) • 91.409(a)(1) 

### & (2) • 91.417(a)&(b) This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act In making this determination , the Secretary is required to determine which types of UAS do not create a hazard to users of the NAS of the public or pose a threat to national security in light of the following: • The UAS's size, weight, and operational capability • Operation of the UAS in close proximity to airports and populated areas • Operation of the UAS within visual line of sight of the operatorReform Act§ 333(a) . Lastly, if the Secretary 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." ld. §333(c). The Federal Aviation Act expressly grantsthe FAAthe authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term defined under §401 01 of the Act, that includes UASs,from the requirement that all civil aircraft must have a current airworthiness certificate. 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 this title if the Administrator finds the exemption in the public interest. 49 USC §44701 (f) See also 49 USC §44711(a) ; 49 USC §44704; 14 CFR §91.203(a)(1). Such operations will insure that the UAS will not create a hazard to users of the national airspace system or the public. Given the small size of UASs and the environment within which they will operate, UAS operations performed by Adam Deets will adhere to the Reform Act's safety requirements. Additionally, approval of this application presents no national security issues. Based on the substantial level of safety surrounding the proposed operations, and the significant public benefit (enhanced safety), reduction in environmental impact (reduced emissions and noise) , the grant of the requested exemption is in the public interest. Accordingly, Adam Deets respectfully requests that the FAA grant the requested exemption without delay. 

### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY UASs to be operated : • DJI Phantom 3 • OJI Phantom 2 • DJI Inspire 1 • DJI S1000 • 3DR Solo Listed above are highly successful consumer grade UASs designed to carry a high definition (HD) camera powered byfour or more electric motors. They utilize an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with a global positioning system (GPS) to maintain its geospatial orientation and position. Itis controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or pilot in command (PIC) to monitor battery level, GPS signal strength, altitude (AGL}, distance from PIC, camera imagery, and control camera angle. All are equipped with a failsafe mode operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight control system and maximum altitude can be preprogrammed by the PIC. The flight controllerliPad will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination offlight and landing will be initiated when the battery reaches a predetermined low state. 

### All UAS operations conducted 

## by Adam Deets will:

• Weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). • Operate at speeds of no more than 50kts, can hover, and can simultaneously move vertically and horizontally. • Flights will be operated within line of sight of a pilot(PIC}. • Limit each operational flight to 30 min or less. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. • Operated at an altitude of no more than 400 feetAGL. • Be operated by a FAA licensed airman with at least a private pilot's certificate and third class medical. • Be operated at a lateral distance of at least 100feet from any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation or who have not signed a waiver in advance of the operation. • Require operators (PIC) to check for any Temporary Flight Restrictions (TFR) by calling 1800WX Brief and a current sectional chart for the area of operation to make sure they will notviolate NationalAirspace System (NAS). • Have the capability to return to a pre-determined location ifthe UAS loses communications or loss of GPS signal. • Have the ability to communicate if needed by radio or phone. Operators (PIC) during all UAS operation have the local Flight Standards District Offices (FSDO) and the closest airport control towers phone number and frequency.• Be entered into a flight log. This allows tracking of UAS maintenance and component intervals as well as proficiency of PIC, thereby enhancing the safety of the program. 

### DISCUSSION OF EXCEPTIONS REQUESTED 14 C.F.R. 

### § 61.113(a) 

### & (b): Private Pilot Privileges and limitations: Pilot in Command Sections 61 . 113(a) and(b) limitprivatepilots to non-commercial operations. Because the UAS will notcarrya pilotorpassengers, theproposed operations can achieve the equivalentlevel ofsafetyofcurrent operations 

### by requiring the pic operating the aircraft to have a privatepilot's license rather than a commercial pilot's license to operate 

### a small UAS. Unlike a conventional manned aircraft, a UAS is remotely controlled by a ground-based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the use of a UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 allowing UAS use by a private pilots as the PIC exceeds the present level of safety sought by 14 CFR §61.113(a) and (b). 14 C.F.R. 

### § 91.7(a) Civil aircraft airworthiness (a) No person mayoperate a civilaircraft unless itis in an airworthycondition. Since no FAA regulatory standard exists for determining airworthiness of the UAS, the regulation will need an exemption . Compliance with operating documents/operating manuals will be sufficient meansfor determining an airworthy condition. 14 C.F.R. § 91.103: Preflight Action Section 91.103 requires each pilot to preflightan aircraftbefore flight to insure the safetyofflight.As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level of safety will be provided. The PIC will take all actions, including reviewing weather, flight battery requirements, Notices toAirmen (NOT AM), landing and takeoff distances, and aircraft performance data before commencement of flight. 14 C.F.R. § 91.119(c): Minimum SafeAltitudes Section 91 .119 establishes safe altitudes for operation of civil aircraft. Section 91. 119 provides /in pertinentpart l that: " ...except when necessary for takeofforlanding /no person mayoperate an aircraftbelow the following altitudes: ... (b) Overother than congestedareas. An altitude of500 feet above the surface /exceptoveropen waterorsparselypopulatedareas. In those cases/ the aircraftmaynotbe operatedcloser than 500 feet to any person I vessel/ vehicle / orstructure. II Because applicant requests authority to operate at altitudes only up to 400 AGL, an exemption is needed to allow such operations. 

### 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 ofthe departure airportoran appropriate altimetersetting available before departure. I I As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption is needed. An equivalent level of safety will be achieved by the operator, pursuantto the safety checklist and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning:"a flightin an airplane under VFR conditions unless (considering windand forecast weatherconditions) there is enough fuel to fly to the firstpointof intendedlanding, and, assuming normalcruise speed - (1) During the day, to fly afterthat foratleast 30 minutes; or (2) Atnight, to fly afterthat foratleast45 minutes. " The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limiting factor. Given the limitations on the UAS an exemption may be needed. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Exceptasprovidedin§ 91.715, noperson mayoperate a civilaircraft unless ithas within the following: (1) an appropriate andcurrentairworthiness certificate. (b) No person mayoperate a civilaircraftunless the airworthiness certificate 

### requiredby

### paragraph (a) ofthis section ora specialflightauthorization issued under§91.715 is displayedatthe cabin orcockpit entrance so thatitis legible to passengers orcrew. The UAS fully loaded weight is no more than 55 pounds and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UASs. An equivalent level of safety will be achieved by keeping these documents atthe ground control point where the controller (PIC) ofthe UAS will have immediate access to them, to the extent they are applicable to the UAS. 14 C.F.R. §91,405(a); 407(a)(1); 409(a)(2); 417(a) 

### & (b): Maintenance Inspections These regulations require that an aircraft operator or owner:
" shallhave thataircraftinspectedasprescribed in subpart E ofthis partandshall between requiredinspections, exceptasprovidedin par agraph (c ) ofthis section,have discrepancies repairedasprescribedin part43 ofthis chapter .. .,"and others shallinspectormaintain the aircraftin compliance with par43. Given that these sections and Part 43 apply only to aircraftwith an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these UAS are very limited in size and will carry a small payload. 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 initiating flight, perform maintenance, and keep a log book of any maintenance performed as well as track all flight hours. The operators the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspection will be performed in accordance with the UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual. As provided in the Operations Manual, the operatorwill ensure that the UAS is in working order prior to initiation flight and perform required maintenance needed. 

### SUMMARY FOR PUBLICATION Applicant seeks an exemption from the following rules: 14 CFR 61 . 113(a) & (b); 91.7(a); 91.1 03; 91.119(c); 91.121; 91.151 (a); 91.405(a) ; 91.407(a)(1 ); 91.409(a)(1) and (2); 91.417(a) &(b). To operate commercially small unmanned vehicle (551bs or less) in aerial photography and videography, real estate photography, aerial surveying and mapping, windmill inspections, cell tower inspections, powerline and pipeline inspection and patrolling, wildlife and forestry monitoring, search operations, construction inspection, general infrastructure, and precision agriculture. Approval of exemptions allowing UASs commercial operations in the areas listed above will enhance safety by reducing risk. A UAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack of combustible fuel carried onboard traditional aircraft performing the same function. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraftflights. The operation of small UAS conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant ofthe exemptions requested herein, including exempting the applicantfromthe requirements of Part 21 and allowing commercial operations. These UASs operate at very low speeds, close to the ground, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. 

### PRIVACY All flights will occur over private controlled areas with the property owner's prior consent and knowledge. Filming will be only of people who have given their consent or otherwise have agreed to be in the area where filming will take place. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security) provide more than adequate justification to grant Adam Deets requested exemption.

If you have any questions or need any additional information, please contact me at 630-640-4424 or 

### adeetsUAS@gmail.com Sincerely,

Adam Deets