Ethan Narber

1/26/16 205 13 th St SW Altoona, IA 50009 ethannarber@gmail.com

Required Additional Information for Section 333 Exemption

**SEEKING RELIEF FROM** Regulations in which Exemption is requested: 14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CF R 409 (a) (2) 14 CFR 417 (a) & (b) 14 CFR Part 21, Subpart H: Airworthiness certificates Seeking exemption from Part 21, Subpart H in that the FAA establishes requirements for airworthiness certificates. Given the small size and nature of the UAS and the limited areas in which it may operate (no higher than 400 feet AGL and not out of visual line of sight of pilot

- in

-command) , exemption from this Part is needed and is still in compliance with the safety under Part 11 and Section 333 of the Reform Act. 14 C.F.R. 45.23(b)

– Display of Marks; general (b) Exemption from Part 45.23 (b) is needed because t here is no entrance to cabin, cockpit, or pilot station on the UAS itself, nor room to display required font & words. 14 CFR 61.113 (a)

- Private Pilot Privileges and Limitations: Pilot in Command Seeking relief from Part 61.113 (a) in that the UAS cannot carry passengers or property, but will be used for compensation in business purposes. 14 C.F.R. 91.7 (a)

– Civil Aircraft Airworthine ssSeeking relief from Part 91.7 (a) in that there is no airworthiness regulation set for the

UAS and there will be no certificate issued for the UAS to have. 14 CFR 91.9 (b) (2)

– Civil aircraft flight manual, marking, and placard requirements Exemption from Part 91.9 (b) (2) is needed because t he UAS does not have the configuration or capacity to carry the required flight manuals, markings, placards, or any combination thereof.
14 C.F.R. 91.103
– Preflight Action Seeking relief Part 91.103 due to the inability to perform a preflight of information in this part. Preflight actions required for the UAS are checking for safety and reliability of the UAS, weather in the area, GPS connectivity, surrounding areas, and referencing location and flight minimums for the UAS.
14 C.F.R. 91.109
– Flight instruction; Simulated instrument flight and certain flight tests The UAS mentioned does not have fully functional dual controls; but is controlled by a remote control via radio communication for flight and operation s. Safety in regards to pilot and passengers is of equal value in that the UAS cannot carry a pilot or passenger.
14 C.F.R. 91.119
– Minimum Safe Altitudes Exemption from Part 91.119 is needed in that the 4

- blade UAS acts primarily as a helicopter woul d, with vertical takeoffs and vertical landings with a typical flight altitude of ~200 feet and up to but 400 feet AGL; but never exceeding 400 feet AGL. All operations with are in civil daylight hours as prescribed by the FAA and in VMC (visual meteorolog ical conditions) only. Careful planning to maintain 500ft from the nearest person, vessel, or structure will be conducted prior to each flight of the UAS. All person(s), vessels, and properties shall be notified if UAS operations should take place within the 500ft distance; and operations will be canceled and/or ceased if permission from one or more participants is not granted.
All operations will remain within visual line of sight (VLOS) in VMC conditions. Exemption is requested so that the UAS may be operated at an altitude lower than the prescribed minimum safe altitudes under Part 91.119. Lower altitudes flown by the UAS will also prevent collisions from fixed

-wing aircraft or helicopters in mid

- air; assuming distance minimums that a UAS must remain from the civil airport and assuming that conventional aircraft are adhering to their prescribed Minimum Safe Altitudes according to their route of flight and/or approach to an airport.
14 CFR 91. 121
– Altimeter Settings An exemption from Part 91.151 (a) is needed in that the UAS does not have an altimeter/pitot static system to have an operating adjustable barometric altimeter foruse of reading altitude. Safety can be maintained by use of an internal GPS altitude

readout from the technology onboard the UAS in addition to the pilot

- in

-command checking the exact altitude of the launch site before takeoff.
14 CFR 91. 1 51 (a)

– Fuel Requirements for flight in VFR conditions Exemption from Part 91.203 (a) & (b) is needed in that the UAS does not have fuel on board for flight. The UAS is equipped with an operating battery pack with only 25 minutes of flight time, and not t he required 30 minutes of reserve fuel in daylight VFR conditions prescribed by this part. Safety measures to prevent battery run out in flight are to limit flights on one battery pack to 20 minutes and no more, and carrying an extra battery pack for every flight that flight operations over 25 minutes are needed. 14 CFR 91.203 (a) & (b)

– Carrying civil aircraft certification and registration Exemption from Part 91.203 (a) & (b) is needed in that the UAS does not have a cabin, cockpit, or pilot station an d is not operated with a pilot on board; therefore there is no option to have certification and registration on board the UAS. Safety measures to comply with this are to have any certification or registration documents on the pilot

- in

command at all times during flight operations from the ground control point where the pilot will be standing. 14 CFR 91.405 (a)

- 14 CFR 407 (a) (1)

- 14 CFR 409 (a) (2)

- 14 CFR 417 (a) & (b)

– Maintenance Inspections Due to the fact that these sections as well as FAR Part 43 only pertain to aircraft with an airworthiness certificate, these sections need not apply to myself, Ethan Narber, or the UAS used during operations. Safety measures will be taken by proper education of parts and assembly of the UAS so that technical is sues and safety hazards can be recognized early before issues can arise. The UAS has the ability to sense abnormalities and can notify the pilot that return to the starting position of takeoff is needed immediately. The UAS also has the ability to fly itse lf back to the starting point if the pilot does not or cannot respond. All maintenance will be made by the operator of the UAS prior to and after each flight operation on a needed basis.

**PUBLIC INTEREST OF GRANTING AUTHORIZATION** Granting this authoriza tion to me, Ethan Narber, will benefit a broad customer base for which the business seeks to market and operate for. The UAS (DJI Phantom 3 Professional) has a wide selection of technological features to keep the operator, and person(s) included in operati ons safe; as well as surrounding person(s), vessels, and property. All additional safety measures to be taken for the interest of safety in public are listed in each individual section for which exemption is requested. Using this specific UAS for various real estate, commercial, and private business practices also leaves a green outlook on business practices. The UAS does not require fuel, and is very environmentally friendly during flight operations. Many operations that are going to beconducted with thes e business practices are currently being done by manned fixed

-wing

or rotorcraft vehicles in the National Airspace System; and by granting this authorization, it will be contributing to less traffic congested in the NAS around large, urban areas with high densities of population. This equates to higher levels of safety in that the small size of the UAS does not pose such a threat as a fixed

-wing aircraft does when maneuvering close to the ground in congested areas of operation. Using this UAS for business p urposes also creates public interest in aviation sector and provides economic benefits to those involved in business transactions. **ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS** I am a licensed Private Pilot with an instrument rating through the Federal Aviation Administration. I have had my Private Pilot’s License since October of 2013. I am well educated and knowledgeable on the Federal Aviation Regulations and National Airspace System. With that knowledge and understanding, I understand what additional safety measures must be taken to safely operate the UAS during operations. **All additional safety measures are in original document for petition of exemption as well as located**  **in this document under each s**  **pecific regulation listed above for which exemption is requested.**  Information regarding the UAS (DJI Phantom 3 Professional) is located in the original petition for exemption (Docket No. FAA

- 2015

-4618).