# SD-01'1

Three Dimemional •Observation Platform Systems

Federal Aviation Administration US Department ofTransportation Docket ManagementSystem 1200 NewJersey Ave. S.E Washington, DC 20590

To Whom It May Concern:
This application is being submitted on 

### my own behalf. 

### I !

. I

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, 3D-OPS, hereby seeks and applies for an exemption to the Federal Aviation Regulations (FARs) to allow 3D-OPS to operate Unmanned Aircraft Systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) underthe conditions and limitations set forth in this petition or as may be established bythe FAA as required by Section 333.1. The requested exemption would permit 30-0PS to operate UAS for the purpose of providing:

• Aerial photography and/orvideo for public and/or private use including real estate,

architecture, land surveying; engineering, construction and other related professional activities; • Aerial video and/or photographyfor publicand/or private use including television, public

events, cinematography and news gatherings; • Aerial inspection/photography of residential/commercial structures, either existing or under·

construction, under contractwith the owners or local government authority; • Aerial inspection/photographyof residential/commercial utility and transportation ·

infrastructure included but not limited to electrical power lines, wind turbines, rail tracks, and cell towers; • Aerial video/photography or providing live video feed to assist with law enforcement

operations, rescue and recovery operations, or cases of an emergency or natural disaster when local authorities or government has requested support with the proper authority;
• The abilityto offertraining to persons or individuals belonging to both private and/or public

organizations that have interests in the use and application of UAS forthe purpose ofthe safe operation ofa UAS to enhance the safety ofnational aerospace system (NAS) as well as for protection ofthe persons and property.

30-0PS johncargy8899@comcast.net 916-**742~S69S**

# SD-OPI

Three Dimensional •Observation Platform Systems

As described more fully below, the requested exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level and safety to currently authorized operations using manned aircraft and underthe conditions as may be modified,by the FAA as required by section 333. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "

...establish requirements forthe safe operation of such aircraft systems in the national airspace system." Section'333(c) ofthe Reform Act. The name and address ofthe applicant is:



## ....**=35~-oJ>s~~·~---** 

## --- contact: John Carey 8800 Creekstone Circle Roseville, CA 95747 916-742-5695 Regulations from which the exemption is requested: 14 CFR 61.113 (a) 

### & (b) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F. R. 91.11914 C.F.R. 91.12114 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 407 (a) (1} 14 CFR 409 (a) (2) 14 CFR 417 (a) 

### & (b)
This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportation to consider whethercertain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaki.ng required under Section 332 ofthe Reform 

### Act. In making this determination, the Secretary is required under Reform Act§ 333(b) to determine which types of UASs do not create a hazard to users ofthe NAS orthe public or pose athreat to national security in light 

### ofthe following:**-~-=--~·-. -~-~~--** **--T~e-UAS!-s-sfre;-weigh~** anrl-operatimlah:apabillty;-· ··- .. -·**-··-~-. ~--**  -·**---~ --·~··**  • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS within visual line of sight ofthe operator. Lastly, ifthe Secretary determines under Reform Act § 333.(c) that such vehicles "mayoperate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system."

. The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

916-74H69S 

### 30·0t'S/1 

# JD·Ofll

Three Dimensi011al •Obsetvation Platfonn Systems

Applicant interprets this provision to place the dutyon the Administratorto not only process·. applications for exemptions under section 333, butfo.r the Administratorto craft conditions for the safe operation ofthe UAS, if itshould be determinedthatthe conditions set forth herein do notfulfillthe statutory requirements for approval.
The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection. (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administratorfinds the exemption inthe public interest. 49 U.S.C. §44701(f} See .also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 {a) (1).
The primaryvehicle to be used will be the OJI Inspire. While vehicles may be upgraded as· new technological and safety advanced occur the barfor operation and safety

### will be set by OJI Inspire and any newvehicles orversions will exceed the current safety and operational standards. No vehicle operated by 30-0PS will be modified from the manufacturers design unless specifically directed bythe same manufacturer.
Brief explanation ofthe OJI Inspire based on data providedfrom manufacturer: The Inspire is a small UAS manufactured by OJI headquartered in Shenzen, China. The Inspire is a four rotor UAS using four brushless motors to provide lift with four 13 inch rotor blades. The motors are controlled by.four electronic speed controllers (ESC) with sinusoidal drive and are specifically tuned forthe Inspire configuration with distinct functional redundancy. The Inspire is powered byan integrated U-Po batterythat is monitored and controlled by an Intelligent Power Management System which provides data tothe PIC with remaining flight time, distance to return home, and estimated time to return home. The Inspire uses dual positioning with intetligent GLONASS 

### +GPS for positioning data. The main controller uses an Inertial Measurement Unit (IMU) with a 6-axis gyroscope and accelerometerto monitor miniscule changes in tilt and movement, thus allowing the UAS to compensate and adjust immediately holding position at all times. Failsafe functions built-in putsthe Inspire on autopilot when needed ifthe battery runs lowor communication with the PIC is lostand returns the Inspire to the recorded "home position" at time of launch. On screen data available to the PIC includes but not limitedto: location map, first person video (FPV), numberofsatellites accessible, height from ground (redundant sensors), horizontal distance from PIC, horizontal speed, vertical speed, battery percent remaining, flight time remaining, time to return home, camera controls, and communication status between remote controller and aircraft. Specs: Weight- 6.47 pounds including battery. Max horizontal speed- 49.2 MPH Max flight time

- "'18 minutes. Dimensions

- 1.4x 1.5 x .99 feet

johncarey8899@

### comcast.net 

### 916-742-5695

# SD-OPI

Three Dimensional

- Observation Platform Systems

Given the small size and weight of our UASs, the applicant falls squarely within that zone of safety (an equivalentlevel ofsafety) in which Congress envisioned that the FAA must1 by exemption, allow commercial operations of UASs to commence immediately. Also due to the size ofthe UASs and the restricted areas in which the relevant UASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafetysurroundingthe proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for photography, the grantofthe requested**·~-,,~00-~~-~=---,,, ~~~f!)ptions**  is iJ1th,epublic interest.l\c:c_ordinglyl the_applicantrespectfully.requeststhatthe c cc-'-o**-~-­** FAA grantthe requested exemption without delay.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
The applicant proposes thatthe exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. Such operations will insure that the UAS will 11not create a hazard to users ofthe national airspace system orthe public." These limitations provide for at least an equivalent or even higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent

### a safety enhancementtothe already safe filming operations conducted with conventional aircraft.
These limitations and conditions to which 30-0PS agrees to be bound when cond·ucting commercial operations under an FAA issued exemption include: 

### 1. The UAS will weigh less than 

### 55 lbs.; 

### 2. Flights will be operated within line ofsight ofthe pilot in command and/or observer; 3. The UAS

### will have a maximum operating speed of no more than 

### 100 mph; 

### 4. Maximum flighttime.f6r each operational flight will be 

### 30 minutes. Flights will be**.,~~"-·--.** -·-- ---- .,. , t.efminated**at-2S%-battefY-pewerreser-v'E!·Gr3(}-miflt~tesof·fltghtdrriewtTichever'··,** -- ··· ···-··· -·-- occurs first; 

### 5. Flights will be operated at altitude of no morethan 

### 400 feet AGL or no more than 200 feet above an equivalent platform from which filming is planned; 6. UAS Pilot will be Pilot in Command (PIC) 7. Minimum crewfor each operation will consist ofthe UAS PIC and a visual observer 

### (VO), the latter ofwhich may serve as camera operator;

. 8. The UAS pilot designated as PIC will have completed the

# manufact~f~e~:~:e~~:ed training/tutorial program, demonstrate

### ~rof!cie_ncy operating specl •c used, and will possess a current State Dnver s Ltcense;

. . 9. No changes to PIC 

### will be made from the time that pre-fhght tS to be performed through the landing of a given flight;

# SD-Ofll

Three Dimensional •Observation Platform Sysrems

10. A briefing will be performed between no.less than the PIC and VO regarding the planned UAS operations priorto each day's flight consisting of all days activities; 11. All flights will occur undervisual flight rules meteorological conditions (VFR only); 12. The PIC and VO will have been trained in operation of UAS and receive up-to-date information forthe particular UAS to be operated; 13. The PIC and VO will be able to communicate byvoice at all times; 14. Ifthe UAS loses communications with the remote controller or loses.GPS signal, the UAS will have the capability to return to a pre-determined location within a designated location and land; 15. The UAS will have the capabiHtY.Jo abort aflight in case of unpredicted obstacles or emergencies; 16. PIC will setthe UAS to automatically return home in event PIC is incapacitated.
As of March 23, 2015, the FAA will automatically grant a "blanket" COA for flights at or below 200 feet to any UAS operatorwith a Section 333 exemption, providedthe aircraft weighs less than 55 pounds, operations are conducted during daytime Visual Flight Rules (VFR} conditions and within visual line ofsight (VlOS) ofthe PIC, and stay certain distances away fromairports or heliports.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft.from the·requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis of these criteria demonstratesthat the UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be atleast as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.
The UAS to be operated hereunder 

### is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored bythe operator. These safety enhancements provide a greater degree ofsafetyto the publicand property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.

30-0PS johpcarey8899@comcast.net 916-742:'5695

# SD-OPI

Three Dimensional

- Observation Platform Systems

lastly, application ofthese same criteria demonstrates thatthere is no credible threat to national security posed by the UAS, dueto its size, speed of operation, location ofoperation, lack of explosive materials orflammable liquid fuels; and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking ofthe Aircraft. The regulation requires: When marks include only the Roman capita/letter "N"and the registration numberis displayedon**limited~** restricted or**light~sport** categoryaircraft or experimentalorprovisionallycertificated**aircraft~** the operatormustalso**.""_,=-~~=~~~·=c--· ~--_fli§play**  on that airCr{}ft

## near eacltent.mnce.to

### thE!**~a:bin,_cackpit** or**¢lot~~~** station, in letters notless than 2 inches normore than 6 inches high, the words "limited," "restricted,"**"light-sport~"** "experimental," or "provisional, '1 as applicable.
Even though the UAS will have 

## no airworthiness certificate, an exemption is needed as theUAS has no entrance to a cabin, cockpit or pilot station on which the word "Experimental" can be placed. Giventhe size ofthe UAS, two-inch letteringwill be impossible.

No person may operate a**U.S.~registered** civil aircraft

... For which an Airplane orRotorcraft Flight Manualis notrequiredby

### §21.5 of this chapter, unless there is available in the aircrafta currentapproved airplane orRotorcraft Flight Manual, approvedmanualmaterial, markings, andplacards, oranycombination thereof.
The UAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

- The equivalent level ofsafety 

### will be maintained by keeping the flight manual atthe ground control pointwhere the pilotflying the UAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737, 8738, 9299, 9299A,9565,9565B,10167,10167A,10602,32827,and10700. 

## 14 C.F.R. §

## 91.103: Preflight action. This regulation requires each pilot in command totake certain actions before flightto insure the safety offlight. As FAA approved

## rotorcr~ft flight

. 

## manuals will not be provided forthe aircraft an exemption 

### will be

## nee~ed. An

## eqUI~alent level of safety will be provided by the 

### PIC in checking the UAS before each fhghtfor

## ~hysscal .. condition, calibration of instruments as required bythe UAS manual, and

## en.sun~g**tha~** all fhght surfaces and controls are consistent with safe flight. The 

### PIC 

### will take all actsons mcludtng

916-742-5695 31)..0PS johncarey8899@comcastnet

# SD-OPI

Three Dimensional •Obsemtion Platfonn Systems

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight.

14C.F.R. §91.109: Flight instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls. UASs and remotely piloted aircraft, bytheir design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and forflight instruction in.experimental aircraft. See Exemption Nos.5778K 

### & 9862A

.. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and bythe size and speed ofthe aircraft.

14 C.F.R. §91.119: Minimum safe altitudes. Section 91.119 establishes safe altitudes for operation ofcivil**aircraft~** Section 91.119 (d) allows helicopters to be operated at less thanthe minimums p.rescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As setforth herein, exceptforthe limited conditions stated in the Manual, the UAS will never operate at higherthan 400 AGL. The equivalent level of safety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. Comparedtoflight operations with aircraft or rotorcraft weighing far more than the maximum SSibs. proposed herein and the lackofflammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL In addition,the low-altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...tothe elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UAS may not have

### a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved bythe**operator~** pursuant tothe Manual and Safety Check list, confirming the altitude ofthe 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 flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions). there is enough fuel to fly tothe first point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat

30-0PS johnqrey8899@**comcast.n~t** 

### 916-742-5695

# SD-01'1

Three Dimensional •ObseiVation Platform Systems

for at least 30 minutes; or (2) At night, tofly afterthat for at least 45 minutes." The battery powering the UAS provides approximately 30 minutes ofpowered flight. To meetthe reserve requirement in 14 CFR §91.151, UAS flights would be limited to no more than 20 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longertime frame forflight in daylightor night VFR conditions is not required. Applicantbelievesthat an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See .Exemption 10673 (allowing Lockheed Martin.Corporation to operate without



### ·FAR**91~151** (a)). OpetatingJ:be-'UAS.cwitb 

### less**tharh3.0:mittuteS'O:f~~ve** fuet**~-.;~C:~-- ~-::_**  does not engenderthe type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe UAS. Additionally, limiting UAS flights to no more than 20 minutes would greatly reduce the utilityfor which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 20 minutes or 25% of battery power whichever occures first. This restriction would be morethan adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.
Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration. The regulation provides in pertinent part: a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following:**1)~** An.appropriate and.current-airworthinesscertificate. ·• .• b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legible to passengers or crew. . t d •thout an onboard pilot. As The UAS fully-loaded weighs no more than 55 lbs and IS opera e

### ~~ d t orto d·tsplay 

### T f d registration ocumen s such, there is no ability

# o~ place to

# ~=r~~**~:~~~c~~~f~::chieved** by keeping these documents at them on the UAS. An equtvalent le ., fl

. the UAS will have immediate access tothem, to the ground control

## poin~ where theh

## P~~S**~~~;FAA** has issued numerous exemptions tothis the extentthey are applicable tot e .**916-742-569~** 3D..OPS johncarJy3899@comcastnet

# / 

# SD·OPI

Three Dimensional •Observation Platform Systems

regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.
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 orowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will not applyto the applicant. Maintenance will be accomplished bythe operator pursuant to the flight manual. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feet AGL As provided in the Manual, the operator will ensure thatthe UAS is In working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety.
The operation ofsmall UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supportingthe grant ofthe exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close tothe ground, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity tothe ground and people.
Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012--size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security- provide morethan adequatejustificationforthe grant ofthe requested exemptions allowing commercial operation ofapplicant's UAS forthe purposes and underthe conditions stated above. Sincerely, John Carey Sole Proprietor 30-0PS 8800 Creekstone Circle Roseville, CA 95747 Johncarey8899@comcast.net 916-742-5695

30-0PS johncarey8899@comcastnet 

### 916-742-5695