James Addison January 4 , 201 6 1163 SE 65 Circle
Ocala

, FL 34472

813

- 368

- 4617 DiveInterval@gmail.com

Petition of James Addison For Exemption Pursuant to Section 333
Of the FAA Modernization and Reform Act of 2012

Dear Director, Flight Standards Service:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11,

I

, J ames Addison

, a FAA Certified Pilot 3003048 hereby apply for an exemption from Federal Aviation Regulations (FARs) identified below to allow co mmercial operations of an u nmanned aerial system ( UAS).

The exemption is in accordance with protocols outlined in this petition for exemption, and any other requirement s established by the FAA pursuant to Section 333 of the Reform Act.

This exemption would permit commercial operations by James Addison , which uses and fl ies a
Phantom 2 V ision + (FAA UAS Certificate Number FA3AYKAFC7) to conduct UAS photography/videography as requested by a third party, UAS flight training, educ ation, real estate photography/ videography, UAS demonstration flights, accident investigation photography/videography, fire investigat ion photography/videography, photography/videography requested by local and state law enforcement agencies , and search/rescue operations . I ( James Addison ) as a n FAA Certified Pilot would be subject to the strict operating requirements and conditions within the current Section 333 exemption and as may be modified by the FAA. This would ensure the same level of safety as is currently authorized in manned aircraft as published in the current FARs by the FAA.

I ( James Addison ) will operate under controlled VFR conditions at low altitude in airspace that is permitted in acco rdance with my ( James Addison ) approved Certificate of Authorization (COA). As an FAA Certified Pilot, and having served as a Lieutenant in the US Army and retired
Lieutenant from the Honolulu Police Department , I have extensive knowledge of the various airspace requirements and will be in a position to not only apply the FARs to my own flying, but also pass that knowle dge on to others interested in UAS flight. Due to my service in the police department and US Army, I also have acquired extensive knowled ge in safety procedures and protocols that will contribute to my abilities to operate under FAA 333.

Page 1I (James Addison) submit this request for exemption because I operate a UAS in the performance of my forensic investigative services where I curren tly analyze the cause and effects that contribute to highway fatalities and serious injuries. I (James Addison) have safely operated the UAS system for approximately 2 years in training and investigative procedures and I have not had any incidents or comp laints regarding the operations of the UAS. Further more , I provide training and investigative services to various law enforcement agencies in Florida and throughout the United States. As a retired Police Lieutenant and FAA certified pilot I have
confidence that the operations I conduct will have a high level of safety incorporated into my operations and will share my knowledge with the various law enforcement agencies. Approval of my exemption would thereby enhance safety and the ability to teach safety as well as fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.”

I ( James Addiso n ) have organized this Exemption request as follows:

1) Petitioner’s Description 2) Relevant Statutory Authority 3) Qualifications for Approval Under Section 333 of the Reform Act 4) Description of Proposed Operations 5) Regulations from which this request for Exem ption is requested 6) Public Interest 7) Privacy 8) Federal Registry Summary 9) Conclusion

1) Petitioner’s Description: I ( James Addison ) am headquartered in Ocala, FL . As an individual, I want to commercially provide UAS service s to third parties requesting photography/ videography, flight training, edu cation, real estate photography/ videography, demonstration flights, accident investigation photography/videography, fire investigation photography/videography, pho tography/videography requested by local and state law enforc ement agencies, and search/rescue operations.

I ( James Addison ) plan to operate in an accident

- free environment by: a) Following all regulation currently published by the FAA and Section 333 b) Identifying an y hazard and risk which would not allo w for the safe operations of a UAS c) Intervene and report when unsafe flying of others appear to exist d) Train others in the safe operation of UAS and instruct them in all applicable

FAA

- FARs

Page 2The contact information for Petitioner (James Addison) is as follows:

1163 SE 65 Circle Ocala, FL 34472

813

- 368

- 4617 DiveInterval@gmail.com

2) Relevant Statutory Authority: This petition for an exemption is submitted to fulfill the goal of Congress when it passed Sect ion 333 (a) through (c) o f the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems (UAS) into the National Airspace System (NAS) before completi on of the formal UAS rulemaking, based on the following cons iderations: 1) The UAS ’ s size, weight, speed, and operational capability 2) Operation of the UAS in close proximity to airports and populated area s 3) Operation of the UAS within the visual line of sight of the operator

If the Secretary determines that such aircraft “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”.

Additionally, the FAA Administra tor has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a request exemption i s in the public interest. A party requesting an exemption must explain why the exemption: 1) Would benefit the public as a whole 2) Would not adversely affect safety and would provide a level of safety equal or better than existing rules.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms , inc ludes exempting civil aircraft, as the term is defined under 40101 of the ACT, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate
aircraft in commercial se rvice:

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of the sections.

3) Qualifications for Approval Under Section 333 of the Reform Act : The proposed operation in this petition for exemption qualifies for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other relevant
factors are satisfied.

Page 3The proposed operations would permit James Addison the use of a UA S under controlled conditions in airspace that is:

1) Predetermined 2) Controlled as to access 3) Provides an increased level of safety beyond that existing when fixed or rotor wing aircraft that are used to accomplish the same purpose

I ( James Addison ) use a UAS that is a multi

- rotor weighing less than 10 pounds including the payload which consist of a gimbaled camera used for photography and videography. The UAS operates only under normal conditions, at an airspeed not to exceed 35 KPH . The UAS has the ability to hover, move in a vertical and horizontal plane

, as well as yaw around its vertical access while in a hover position. In addition, I ( James Addison ) will operate in a (not to exceed) line of sight mode. The UAS that I ( James Addison ) operate has a pre

- programmed AGL limit of 300 feet which is 100 feet below the Section 333 altitude height limit. A NOTAM will be filed for each flight that operates in controlled airspace and would first be approved by the controlling FAA facility. All required permissio n s and permits would be obtained from the controlling government agencies prior to operating a UAS

.

Given the small size and light weight of the UAS involved and the environment in which operations will take place the exemption that I ( James Addison ) am requesting f alls within the zone of safety in which Congress desired the FAA to permit commercial UAS operations by exemption pending completion of formal rulemaking. In addition

, because of the size, weight and qualifications/experience of the opera tor, approval of this exemption presents no hazard in
the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed

opera tions, and the significant public benefit, the granting of this requested exemption to
James Addison

– a FAA Certified Pilot is also in the public interest.

4) Description of Proposed Operations: To assist the reviewer of this exemption request

, I ( James Addison ) offer a summary of the operational limitations and conditions that will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

a) The UAS used will weigh less th an 10 pounds including its payload.

Page 4b) Flights will be within line of sight and at or below 300 feet AG L of the PIC

. c) M aximum total flight time will be limited to 20 min and/or 25% of the reserved battery power whichever occurs first. d) Flights will be conducted at a distance of at least 100 feet from any inhabited structure, building, vehicle, vessel, people not associated with the operation
of the UAS

. e) Minimum crew for each operation will consist of the PIC ( James Addison ) and a designated visual observer. f) The UAS PIC ( James Addison ) has undergone comprehensive UAS flight training for competency and has studied FAA 333 as well as Part 107 commercial compliance requirements

. g) James Addison will be the only PIC for each mission associated with this exemption request. h) Prior to ea ch commercial mission at a particular location, a site inspection will be conducted to insure that all of the flight requirements associated with
the Section 333 are met

. i) I ( James Addison ) will use a checklist and callouts associated with the Operations Ma nual

. j) The UAS will be maintained in accordance with the inspection program outlined in the manufacturer’s guidelines

. k) In the unlikely event of an accident

, I ( James Addison ) will cease operation and report the accident to the appropriate government authority. l) The PIC and the Visual Controller will at all times be able to communicate by

voice

. m) T he PIC and Visual Observer are trained in accordance to FAA, NTSB, and

AFS

- 80 best practices. n) All required permission s and permits will be obtained from the local government agencies before a flight is conducted

. o) If the UAS loses communication signal with the flight controller, the UAS will
have the ab ility to return to the launch location and land automatically

. p) The UAS has the ability via the PIC controller to abort a flight in case of unpredicted obstacles or emergencies. q) I ( James Addison ) by following FAA, NTSB, and AFS

- 80 best practices

, will assure that no individuals’ privacy is violated

. r) I ( James Addison ) will con tact the controlling ATC facility prior to operating in airspace other than G.

Page 55) Regulations from which this Request for Exemption is requested :

A ) 14 CFR

– 91.103

– Preflight Action

B) 14 CFR

– 91.113

– Right

- of Way Rules

C) 14 CFR

– 91.119 (c)

- Minimum Safe Altitudes

D) 14 CFR

– 91.121

– Altimeter Settings

E) 14 CFR

– 91.151 (b)

– Fuel Requirements for Flight in VFR Conditions

G) 14 CFR

– 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), 91.417 (a) and (b)

– Maintenance Inspections

A. 14 CFR § 91.103: I ( James Addison ) requests an exemption from the preflight actions requirements of 14 CFR 91.113 that prescribes the preflight actions under which aircraft may operate:

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. a. Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternative s available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC; b. For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance inform ation: i. For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and ii. For civil aircraft other than those specifi ed in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and
temperature.

I ( James Addison ) will not operate a UAS under IFR conditions or when the ceilings are below 1000 feet and the visibility is below 3 statute miles.

Equivalent Level of Safety : In adherence to FAA, NTSB, and AFS

- 80 best practices, the PIC will assure that the weather will be adequate to complete the
mission in VFR condition.

Page 6B. 14 CFR 91.113: Right

- of

- Way Rules : I ( James Addison ) request an exempti on from 14 CFR 91.113 Right

- of

- W ay rules, requiring vigilance by each person operating an aircraft so as to see
and avoid other aircraft. When a rule of this section gives another aircraft the right

- of

- way, the pilot shall give w ay to that aircraft and may not pass over, under, or ahead of it unless well
clear.

I ( James Addison ) operate a small pilotless UAS and cannot comply with these rules as they have been written.

Equivalent Level Safety Flying : I ( James Addison ) operate a UAS at or below an altitude
of 3 00 feet AGL, well below the normal operating altitude of other aircraft. I personally
oversee each mission and have knowledge of the see

- and

- avoid rules. A Visual Observer will assist the PIC in looking for aircraf t entering the operations area. It’s the responsibility of the PIC to cease operations and land the UAS immediately whenever
and aircraft comes into th e vicinity creating a potential threat. Operations cannot
recommence until the threat is clear.

C. 14 CFR. § 91.119: Minimum Safe Altitudes Flying : I ( James Addison ) request an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe altitudes under which aircraft may operate: • Over any congested area of a city, town, or settlement, or over any open air assembly of

persons, an a ltitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. • Over other than congested areas at an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, t he aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended operations, the UAS is normally operated below 3 00 feet AGL. Additionally, due to the nature of the proposed operations, the UAS
will maintain a horizontal distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation.

Equiva lent Level of Safety : Compared to the flight of no rmal aircraft, I operate a
multi

- rotor aircraft w eigh ing less than 10 pounds, and given the lack of fuel, any risk associated with these operations is far less than those that presently exist

Page 7using conventional aircraft. An equivalent level of safety will be achieved given
the size, weight, and speed of the UAS, as well as the location where it is operated. As set forth in the FAA, NTSB, and AFS

- 80 best practices, the UAS will be operated w here buildings and people will not be exposed to operations without their pre

- obtained consent. Because of the advance notice to the property owners and participants, all affected individuals will be well aware of the planned flight operations prior to commenc ement of operations. Furthermore, by operating at such lower altitudes, the UAS will not interfere with aircraft that are subject to the mini mum safe altitude regulations.

D. 14C.F.R. § 91.121: Altimeter Settings : I ( James Addison ) seek an exemption
fro m 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required because the UAS does not have a barometric altimeter, but rather a
GPS altitude read out.

Equivalent Level of Safety : An equivalent level of safety will be achieved by following the procedures set forth in the FAA, NTSB, and AFS

- 80 best practices. I
will confirm the alt itude of the launch site shown on the GPS altitude indicator before flight. Moreover, as the PIC , I will use the GPS altitude indicator to constantly monitor the UAS height, thus ensuring operation at safe altitudes.

E. 14 CFR 91.151(a) F uel Requirements for Flight in VFR Flying Conditions: I ( James
Addison ) requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Section91.151 states: a. No person may begin a flight in an airplane
under VFR conditi ons unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and assu ming normal cruising speed

– i. During the day, to fly after t hat for at least 30 minutes; or ii. At night, to fly
aft er that for at least 45 minutes.

The batteries powering the Phantom 2 Vision+ provide approximately 10 to 25 minutes of powered flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151, UAS flights could not be conducted. Giv en the limitations o n the UAS proposed flight area and the location of its proposed operations within a predetermined area, a safety margin based on a reserve amount of battery life is
needed.

Page 8Equivalent Level of Safety : An equivalent level of safety will be achieved because the operations will be conducted on

- site without significant transit time by the UAS . All flights will be planned to terminate with no less than 25% reserve battery power still available. This restrict ion would be more than adequate to
return the UAS safely to its planned landing zone from anywhere in its confined area of operation even in the event of an unexpected occurrence. Operation of
the UAS with less than 30 minutes of reserve fuel does not incl ude the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of
the UAS , and the proximity of the flight op eration to the landing zone.

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b):

Maintenance Ins pections : I ( James Addison ) also seeks an exemption from the maintenance inspection requirements contained in 14 CFR 91.405(a), 91.407(a) (1), 91.409(a) (2), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) (stating that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections h ave discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the UAS will not have.

Equivalent Level of Safety : An equivalent level of safety will be achieve d because maintenance and inspections will be performed in accordance with FAA, NTSB, and AFS

- 80 best practices. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maint enance performed. 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. If mec hanical issues arise, the

UAS size and carrying capacity, and t he fact that flight operations will only take place in restricted areas for limited periods of time, creates less risk than that associated with conventional rotorcraft performing the same operation.

6) PUBLIC INTEREST : Granting James Addison a n FAA exemption furthers the public interest. National policy set by Congress favors early integration of the

UAS into the national airspace in controlled, safe working environments such as those pr opose in this petition. The vision I have is to help facilitate safe integration of UAS ’s into mainstream USA i n the following areas:

• Photography and Videography where the shot requires unique vi ews.

Page 9• News Gathering

- Similar to movies and videography, each ne ws assignment

may require a completely different shot or view of a scene. With budgets for traditional helicopter use being greatly reduced, the UAS is the perfect solution to allow for easy news gathering for a fraction of the cost. The UAS can be operated in a sterile area away from the public, while t he traditional helicopter
must operate over persons and property increasing the danger to individuals.

• Real Estate

- The UAS can be used in all areas of real estate, including commercial, residential and industrial prop erties. Using a UAS , real estate professionals can create promotional videos, photos and unique shots that normal camera aspects ca nnot capture. The UAS creates an easy

- to

- use video and photo platform which enables properties to stand out, providing dazzl ing views that are typically shown via expensive computer animation or costly
helic opter rentals.

7) Privacy : I ( James Addison ) am deeply committed to protecting public privacy. As a skilled UAS Pilot I am well aware that many individual s have concerns about privacy from the operat ions of UAS ’s.

8) Federal Registry Summary : Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: I ( James Addison ) seeks an exemption from the following rules: 14 CFR § 91.103; 14 CFR § 91.113; 14 CFR § 91.119 (c); 14 CFR § 91.121; 14 CFR § 91.151(b); 14 CFR § 91.405(a), 91.407(a) (1), 91.409(a) (2); 91.417(a) and (b).

Approval of this exemption r equest allows James Addison to conduct commercial operations with small and lightweight unmanned a erial systems. My singular vision is to enhance safety of UAS operations in the NAS while reducing risk to the general public and property owners.

The Phantom 2 Vision+ we ighing less than 10 pounds and powered by batteries and electric motors, eliminates virtually all of that risk given the reduced mass
and lack of combustible fuel carried on board. The UAS is transported to the designated mission area and set up there. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of this UAS will provide an equivalent level of safety supporting the grant of the exemptions requested herein, i ncluding exempting the applicant from the requirements of several regulations and allowi ng commercial operations. The lightweight UAS will operate at slow speeds, close to the ground,
and in a sterile env ironment. As a result, it is far safer than conv enti onal fixed wing aircraft or helicopters.

Page 109) Conclusion: For the foregoing reason, it is requested that the regulatory exemptions requested herein be granted, and the Petitioner ( James Addison ) be permitted to conduct commercial operations using a UAS based on the aforementioned purposes.

If additional information is required, or if you have any questions regarding this Petition for Exemption, ple ase contact the undersigned at:

James Addison
1163 SE 65 Circle Ocala, Florida 34472

813

- 368

- 4617 DiveInterval@gmail.com

Submitted By: James Addison Dated: January 4 , 201 6

Page 11