5/29/2015 Jason Spradley High Above SBC 6024 Summerville Ln Bossier City, LA 71111 (512) 221-7360 

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. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590
To Whom It May Concern: I, Jason Spradley, am writing to request exemption from the following sections ofTitle 14, Code ofFederal Regulations§§ in accordance with the FAA's Guidelines for Submittinga Petition for Exemption under section 333 ofthe FAAModernization and ReformAct of2012. 91.119(c), .91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a)&(b). I am requesting this exemption in order to operate small unmanned aircraft systems (sUAS) commerciallyin airspace regulated bythe FederalAviation Administration (FAA) for the purposes ofaerial photography / video, real estate marketing and surveys, and other flight requests that couldbe performed safely and more cost effectively with the use ofsUAS at low altitude (below 200 feet) within the U.S. national airspace system as compared to a manned aircraft

. Such requests will onlybe performedwith the authorization and permission ofclients or authorized agents ofsuch clients. No persons will be included in anyphoto/video without theirexpressed written permission, which will bekept onfile for audit at any time bythe FAA

. The following reasons for exemption ofthe above mentioned Federal Aviation Regulations (FAR) are being requestedby myself, Jason Spradley. 

## > 91.119(c) As determined in the Exemption 11138 (Douglas Trudeau)

- operations conducted closer than 500 feet to the ground may require thatthe UAS be operated closer than soo feet to essential persons or objects that would not be possible without additional relief. The petitioner requests modification or exemption and clarification concerning the terms 

### congested areas and 

### densely populated. I am requesting a waiver for this condition to allow responsible operation with extreme safetyin areas with housing and possible other structures. 

## > 91.121 As determined in exemption 11138 (Douglas Trudeau)

- is nonapplicable since the the sUAS does notuse an altimeter but does utilize electronic GPS with a barometric sensor for altitude hold and information. );> 91.151(a) As discussed in exemption 11136 (Advanced Aviation Solutions LLC)

- prior reliefhas been granted for manned aircraft to operate atless thanthe prescribed minimums, including exemption numbers 2689, 10650, and 5745· Additionally, similar UAS specific reliefhas been granted in exemption numbers 10673, 8811, and 10808for daytime visual field ofreference conditions (VFR). The UAS provides batterypower measurement to the radio controllerheld bythe person in control (PIC). The UAbatteries allow for apporoximately 20 minutes offlight. I have attached information on UASs that describe in more detail the specifics around battery management. They contain process and procedures for the PIC when batteryreaches a certain level. Understanding the limitations on 

### proposed operations andlocation ofsaid operations, the FAA

### found

**~** that reduced minimum power reserve for flight in daytime VFR Vl

**~** conditions was reasonable

. 0

**~** );> 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), 91.417(a) & (b) ..c 

### ¥ As discussed in exemption 11138 (Douglas Trudeau)

- I, Jason 

# •u ro Vl Q) > 0 ..0 <( _c rn I Spradley, will personallyinspect and ensure that each UAS is in top conditionfor safe flight in accordance with all documents pertaining to safe operation. The FAA found that adherence to the petitioners operating documents and the conditions and limitations specified, describing the requirements for maintenance andrecord keeping and inspection were sufficient to ensure that safety would not be adversely affected.
Description ofUAS to be Operated under this Exemption The DJI Phantom 3 professional andthe Yuneec Qsoo areboth manufacturedbyhighly successful and safety oriented companies. Both UASs fly under 25 pounds and carryhigh definition cameras. The advertised maximum speedis less than 15 miles perhour and is poweredby four electric motors with a distance ofless than 18 inches. Theyboth utililize gps and compass orientation for stable flight andthe ability to knowtheir position at all times. The gps onboth UASs also do not allow for motors to be initialized within a designated No Fly Zone. Real time video that includes telemetry is visible bythe PIC at all times. The PIC can measure batterylevel, GPS strength, altitude, distance from PIC, along with image from camera at all times. Both units have fail safe modes of operation for lowbattery, loss ofgps orloss of signal. In these situations, the UAS will return to the point oftakeoffand motors will automatically disengage. Each UAS can beprogrammed to limit their altitude and distance from PIC before flight. Both units are also limited to approximately 20 minutes perbattery. Both units also have visible LED indicators thatlet the PIC know ofany situation that the PIC might determine requires the UAS to return home. Most flights last less than 10 minutes and more information is available in the attachments that I have included with this application for exemption. Acknowledgment ofF AASafety Regulations and Guidelines I, Jason Spradley, have reviewed and retained a copy ofall FAA regulations including those regulations and guidelines based on the premise ofsafety. I find all regulations to be reasonable and I will not only meet, but do myu CD lfl Q) > 0 .D <( ...c en I best to exceed all safetyregulations as setforth bythe FAA

. My main focus is safety and protection ofall persons and propertythat myselfor my UAS comes in contact with. I have enclosed documents that include a preflight and postflight checklist, but I also have an additional checklist that I use before, during and after each flight. All moving parts ofthe UAS are inspected to ensure safety. Request for Close Proximity Flight I, Jason Spradley, am also requesting to be allowed to operate within 5 miles ofan airport similar to reference number 1, providing that


### "The UA may not operate in Class B, C, orD airspace withoutwritten approval from the FAA. The UA may notoperate within 5 nautical miles of the geographic center of a non towered airport as denoted on a current FAApublished aeronautical chart unless a letter of agreementwith that airport's management is obtained, and the operation is conducted in accordance with a NOT AM

### as required by 

### the operator's COA

. The letter of agreementwith the airportmanagement must be made available to the Administrator upon request."

I have permission ofthe airport administrator or designated official. I will have written permission and a documentedflight plan for each flight used in this manner. The before mentioned written permission andflight plan will be kept on file for audit at any time for the FAA. Flight within 5 miles of an airport is rare, butin the area I plan to operate, there are several small airports that allow UAS flight within 5 miles with permission as noted above.
Other Interests I feel that this exemption will allow me not onlythe ability to gain financially for use at the request ofdifferent companies, butit will also allow me to help educate the public on the safe use ofa UAS under proper legal guidelines and safety. I feel that this exemption will also allow me to perform tasks that not only could not be performed from the ground, but would also allow me to perform tasks that would normally putpersons at 

# •u co Vl Q/ > 0 ..D <! ..c. en I risk to obtain the same information. Many ofthe structures I would be filming would be hazardous for an individual to access. The use ofa UAS allows for safe visual inspection ofnot only property, butbuildings and other structures as well. I can also use the UAS to participate in air shows and displays for no charge to showthe many uses ofthis type ofaircraft when performed under the properlegal guidelines. My services 

### will also be offered to local organizations such as schools, fire departments, and police departments as long as such requests fall under the rules ofthe exemption that I am requesting along with all other FAA guidelines. Operations for this petition will also enhance the economic growth ofthe area in which my company resides

. 

### Summary I, Jason Spradley, am requesting this exemption for the purposes ofaerial photography andvideo of, not only real estate, butpossibly land observation, inspection ofconstruction equipment, towers, and otherflight operations as requestedby clients. I am requesting this exemption for the reasons noted above and specifically intended these items to be broad based on my business plan to extend operations to different areas based on requests by clients. Each request will be analyzed by myself, Jason Spradley, to validate that these requests canbe done in a safe manner and in compliance with all FAAregulations

. I also plan to use mybusiness and myself as a mentorfor other small business owners to educate and to assist them in starting their own business in accordance with all FAA regulations and laws. I have seen several advertisements ofpeople offering these services, as specified above, but I have refrained from pursuing opportunities for commercial use ofmy UAS until I can properlybe authorized bythe FAA.


### Personal Information I am a member ofthe AMA, Member # 1071321. I have been flying RC aircraft for over 2 years with no incidence and I am an avid builder ofRC models to include cars, helicopters, and UASs. I have a passion for the 

# •u co l/) QJ > 0 ..0 <! ..c 01 I hobby and I have been waiting for the opportunityto possibly turn that hobbyinto a venture that would help support myfamily

. 

### DocumentsAttached 1. DJI Phantom 3 Professional Safety Guidelines 2. Yuneec 

### Qsoo Owner's Manual 3. Yuneec Q500 LED Indicators


### References 1. FAA Exemption Number 11080, Regulatory Document Number FAA2014

-0355 in the matter ofthe petition ofFlying Cam INC 2. FAA Exemption Number 11136, Regulatory Document Number FAA

2014

- 0508 inthe matter ofthe petition ofAdvanced Aviation Solutions LLC 3. FAA Exemption Number 11138, Regulatory Document Number FAA2014-0481 in the matter ofthe petition ofDouglas Trudeau
Thankyou for your consideration ofmypetition for this exemption. I look forward to hearing from you soon. Please do not hesitate to reach out to me with any questions or ifany additional information is needed. Respectfully,



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