June	2,	2015

FROM: Gary	Buzel 8211	Vincetta	Dr.,	Apt.	16 La	Mesa,	CA		91942

- 2440
858

- 361

- 9711 gbuzel@gmail.com

TO: U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	S.E. Washington,	DC		20590

Subject: Exemption	Request	under	section	333	of	the	FAA	Reform	Act and	Part
11	of	the	F ederal	Aviation	Regulations	contained	in	14	CFR:	45.23(b),	91.103, 91.109,	91.119,	91 .121, 91.151(a),	91.203(a),	91.7(a),	91.9(b)(2),		91.405(a), 91.407(a)(1),	91.409(a)(2),	91. 417(a)(b).

To	whom	it	may	concern:

I	am	writing	the	exemption	request	on	my	own behalf,	acting	as	pro	pur

- without	counsel.

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012 (the	“Reform	Act”)	and	C.F.R.	Part	11,	Gary	Buzel	(p etitioner,	applicant,	operator, operational	control) ,	owner	and	operator	of	a	Small	Unmanned	Aircraft	System (sUAS)	seek	exemptions	from	Federal	Aviation	Regulations	detailed	herein	for	the operation	of	lightweight	aerial	imaging	equipment	for	the	purposes of	aerial photography,	videography,	and	for search	and	rescue	operations.The	reason	this	applicant	is	requesting exemptions	from	the	listed	Federal Aviation	Regulations	is	to	allow	for	commercial	operation	of	a	sUA	to	collect	aerial images /video for re al	estate,	weddings, newsgathering,	and	search	and	rescue events	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	333.1.

The	Petitioner /Operator :

The	petit ioner

– Gary	Buzel has	been	a	licensed	pilot	since 1995 currently holding	an	Airline	Transport	Pilot	Certificate	(#3003234) for	Multi	Engine	Land	and
CE

- 500	( Cessna Citation	II	Jet)	type,	and	Commercial	Pilot	Privileges	for	Single Engine	Land	and	Sea	Airpl ane.		The	petitioner	also	holds	a	Certified	Flight	Instructor Certificate	(#30 03234	CFI)	for	Airplane	Single/ Multi	Engine	and Instrument Airplane.		T he	petitioner	holds	a	Ground	Instructor	for	Instr ument	and	Advanced. The	petition er	has	3990	hours	total	t ime,	3872 in	airplanes,	18	in	rotorcraft ,	and	has been	a	past aviation	safety	counselor	with	the	Bradley International (Windsor Locks,	CT	KBDL)	flight	standards	district	office	(FSDO)	under	the	leadership	of	FAA Aviation	Safety/Operations	Inspector	James	A dams.

The	petitioner	has 5	years experience	in	aerial	photography	from	Cessna 172,	182	and	PA

- 28

- 181 manned aircraft platform .		The	petitioner	has	been	flying model	aircraft	since	he	was	13,	and	has	been	flying	sUAS	“quadcopters ”	for	2	years as	a	hobbyist	and has approximately	200	hours	of	total	sUAS	time.

The	petitioner	has	instilled	safety	protocols	derived	from	his	training	as	a
manned

- aircraft	professional	pilot	in	combination	with	working	with	interests	on the	ground	to avoid	and	prevent	an	sUAS	being	a	public	hazard both	in	the	air	and on	the	ground

. The	petitioner	is	available	to	offer	assistance	to	the	FAA	in developing	operati onal	and	safety	protocols	for	s UAS’s to	be	integrated	into	the National	Airspace	System	(NAS).		The	petitioner	believes	that	his	exemption,	if granted,	would	provide	the	FAA	with	an	analytical,	expanded	and	diverse	sUASexperience	to	help	establish	the	necessary	requirements	and	protocols	fo r	the	safe operation	of	such	aircraft	systems	in	numerou s	applications	within	the	NAS.
Aircraft

The	petitioner	will	operate	a	sUAS	made	by	manufacturer	DJI,	model	Inspire 1/T600. Serial	number	W13DCA16020308,	FAA	registered	under	tail	number
N774GB. T he	I nspire	1/T600	description	and	equipment	is	as	follows :

• The Inspire	1/T600	is	a	sUAS	quadcopter	made	by	DJI	that	has	a	fixed camera	gimbal	attached	to	a	4K	camera	which	sits	below	the	aircraft fuselage. This	camera	allows	the	operator	on	the	ground	to see	a	720P	high
resolution	a	view	from	the	aircraft that	can	be	rotated a	360	degree	angle	in

flight.

• M ax	takeoff	weight	is	6.47	pounds

• D ownlink	telemetry	to	allow	the	operator	to	see	onboard	information relating	to	safe	operations	of	flight	including	b ut	not	limited	to ; battery percentage	remaining,	overall	status	of	flight	systems,	GPS	location	for position	hold,	auto	return	to	home,	and	operational	failsafes.

• The	Inspire	1/T600	is	limited	by	its	software	to	a	maximum	ascent	rate	of 984	feet	per	minute and	an	altitude	of	400	feet.		Its	maximum	forward	speed is	49	statue	miles	per	hour	or	37	knots.

• The	Inspire	1/T600	is	powered	by	a	5700	mah, 22	volt	battery,	providing	22
min u t es	of flight time	under	standard	conditions per	specifications

. The
aircraft alerts	the	operator	with	visual	and	audible	warnings	at	35%	of battery	remaining.		The	aircraft	will	not	be	operated	in	the	air	with	less	than 35%	of	battery	remaining,	and	0

- 35%	is	kept	as	emergency	reserve	to	power the	sUAS	to	a	safe	landing	location	in the	event	of	an	emergency.

Ground	Based	Control and	Communications System• The	Inspire	1/T600	is	controlled	using	a	DJI	manufactured	transmitter, operating	on	FCC	authorized frequencies	of	the	2.4	GHz band (2

. 4

– 2.483 GHz)		See	Manual	page	57	for	radi o	transmitter	specifications.			The transmitter	has	been	approved	by	the	Federal	Communications	Commission and	bears	approval	logo	on	the	transmitter.

• The	above	listed	transmitter	has	a	lithium	polymer	battery	powering	the	unit
for approximately	4	hours time	between	charges	according	to	DJI specifications.

• The	Inspire	1/T600’s	controller	will	be	utilized	by	a	single	operator,	but	will require	a	visual	observer	when	necessary

• The	Inspire	1/T600	when	coupled	with	an	Apple	iPad	Air	2	provides	the operator with	a	moving	map	display	showing	exact	aircraft	position,	and	HD
video	from	the	aircraft	camera.		Also	the	controller	has	it’s	own	GPS	receiver establishing	a	“home	point”	on	each	take	off,	therefore	calibrating	the	aircraft to	return	to	this	takeoff	poin t	in	the	event	of	a	control	link	signal	loss	or
interference.

• Gary	Buzel

– the petitioner/operator	while	engaged	in sUAS flight under	this exemption will	be	carrying	a	Yaesu FTA

- 550,	Air	Band	communications	radio serial	number	#4N100614.		The	radio	is	capable	of	transmitting	and receiving	radio	signals	on	the	IACO	radio	aviation	band	of	118.000	to 136.975	MHz.		The	radio	has	a	transmit	power	output	of	5	watts	AM	PEP.
While	t he	sUAS	is	in	flight	in	Class	G	and	E	airspace	the	operator,	and/or observer	will	monitor	“guard”	frequency	of	121.500	MHz.		If	operations	are in	controlled	airspace	Classes	B,C,D,E,	the	operator	will	monitor	and
communicate directly	if	needed	with	the	ATC facility	in	charge	of	thatrespective	airspace.		Communications	with	ATC	will	be	standard	aviation communication	etiquette /procedures utilizing	the	sUAS’s	“N”	number	issued by	the	FAA	registration	branch	to	identify	this	aircraft	to	ATC.		Having	real
time radio	communications	with ATC	and	nearby	aircraft	we	believe adds	a significant	margin	of	safety	to	our	operation	and	the	operations	of	other manned	aircraft	in	the	NAS.		The	operator also holds	an	FCC	restricted	radio telephone	operator	permit.

• Gary	Buz el	will	be	t he	sole	operator	of	the	s UAS	for	each	flight,	and	when necessary	will	partner	with	a	Visual	Observer	to	assist	in	keeping	in	sight	the sUAS	at	all	times.		The	Visual	Observer	will	assist	the	operator	with	obstacle clearance,	people	separation	a nd	navigation	over	terrain.

Operator ’s

- Safety	Plan

• Compliance	with	all	FAA,	state,	and	local	municipal	regulations

.

• Altitude	of	operations	less	than	400	Feet	AGL, although most	operations	will
be	at “tree	line	level”	or	under	200	feet

.

• Preflight aircraft inspection s conducted	prior	to	each	flight	per	DJI Inspire1/T600	operators	guide.

• Postflight aircraft inspection	conducted	to	each	flight	per	DJI	Inspire1/T600 operators	guide

• Operator	will	conduct	preflight	planning,	to	include	a	weather	briefing via DUATS	or	FSS,	NOTAM/TFR /MOA checks,	battery

- power	management calculations, and	any	COA	requests or	ATC/Airport	management
notifications done	before	flight

.

• No	operations directly over	people	or	crowds

.• Operations	will	be	only	during	daylight	times ,	in	VMC	conditions,	weather minimums	include	500	feet	below,	2,000	feet	horizontal	from	clouds,	and minimum	3	statue	miles	visibility.			No	Special	VFR	or	IFR	flights	will	be
conducted.

• Any	inflight	emergencies	will	result	in	an	immediate	landing.		Ther e	will	be no	“land	when	practicable”	operations.

• The	Inspire	1/T600	will	be	maintained	per	DJI	instructions,	and	will	follow manufacturer	safety	bulletins.

• If	operating	near	an	airport	or	in	Class	B,C,D	airspace	under	a	COA,	operator will	notify	ATC	vi a	telephone	prior	to	takeoff	and	notify	via	radio	utilizing	the sUAS’s	tail	number.		If	radio	or	telephone	communications	cannot	be
established	with	ATC /Tower ,	the	flight	will	not	commence.

• When	operating	inflight,	operator	will	monitor	“GUARD”	frequency of	121.5 MHZ	and	comply	with	any	emergency	requests	if	received.

• Operato r	will	grant	right	of	way	to	ALL other	manned	operations	and
activities	at	all	times. Lastly,	the	petitioner’s	safety	plan	is	to	operate	the	aircraft	within	the	limitations provided by	DJI

– The	manufacturer. This	is	to	include,	weight	and	balance,	speed limitations,	and	altitude	limitations.

Statutory	Authority

Section	333,	titled	“Special	Rules	for	Certain	Unmanned	Aircraft	Systems,” provides	a	mechanism	for	seeking	expedited	F AA	authorization	of	safe	civil s UAS operations	in	the	National	Airspace	System	(NAS).		Section	333(a)	states	that	the FAA	“shall	determine	if	certain	unmanned	aircraft	systems	may	operate	safely	in	the national	airspace	system	before	completion	of	the	comp rehensive	plan	and rulemaking	required	by	section	332(b)(1)	of	this	Act	or	the	guidance	required	by section	334	of	this	Act.”		In	Section	332(b)(1),	Congress	made	it	clear	that	Section 333	provides	a	mechanism	for	“expedited	operational	authorization.”		Th e	FAA	hascommitted	to	complying	with	this	mandate	by	granting	several	petitions	almost
identical	to	the	one	at	hand. See,	e.g.	Exemption	No.	11062,	Regulatory	Docket	No.
FAA

- 2014

- 0352	(granting	regulatory	exemptions	to	Astreus	Aerial	for	operation	of

unm anned	aircraft	systems	for	the	purpose	of	filming	for	the	motion	picture	and television	industry	and	aerial	videography).

Section	333(b)	identifies	several	factors	that	the	FAA	should	consider	in determining	whether	commercial s UAS operations	should	be	approved.		These
include s UAS	that,	“as	a	result	of	their	size,	weight,	and	speed,	operational	capability, proximity	to	airports	and	populated	areas,	and	operation	within	visual	line	of	sight
do	not	c reate	a	hazard	to	users	of	the	NAS or	the	pu blic	or	pose	a	threat	to	national security.”		See	section	333(b).

In	addition	to	the	specific	authority	conferred	by	Section	333,	the	FAA Administrator	has	general	authority	to	grant	exemptions	from	the	FAA’s	safety regulations	and	minimum	stan dards	when	the	Administrator	decides	a	requested exemption	is	in	the	public	interest.		See	U.S.C. § 44701(f)

Requested	Exemptions

14	CFR	Part	21 and	14	CFR	91.203(a) : Airworthiness	Certificates

The	petitioner	seeks	exemptions	to	apply	for	and	maintain airwo rthiness
certification	for	our	s UAS.		Model	and	serial	numb ers	of	our	sUAS	is	provided	above.

The	petitioner	will	keep	his	sUAS	in a	safe,	reliable,	and	airworthy	condition,	but	it may	not	meet	all	standards	set	forth by	part	91.203.		Petitioner/op erator	will assume	all	responsibility	for	determining	that	the	sUAS	is	in	a	condition	safe	for flight,	as	well	as	a	condition	that	will	not	harm	other	people	or	property.		This	will be	facilitated	by	operator	using	specific	guidelines	from	the	manufacturer ,	DJI,	as well	as	following	any	guidance	set	for	ro utine	maintenance.14	CFR	45.23(b) : Display	of	Marks;	general

Under	this	part	it	is required that	each	operator	must	display	on	that	aircraft	marks consisting	of	the	Roman Capital “N”	followed	by	the registration	number	of	the
aircraft.		And	near	the	entrance	to	the	cabin or	canopy	etc., in	letters	between	2

- 6
inches	in	size	the	word	“ experimental .”..

The	Inspire	1/T600	sUAS	is physically too	small	to	place “ N ” numbers	and

“ experimental ” identifiers o f	this	size specified	in	this	section

. We	can	comply completely	with	an	“N”	number	and	the	“experimental”	identifier	but	at	a	smaller
size (around	1”)	is	necessary to	fit	on	the	external	shell	of	the	Inspire1/T600	sUAS.

14	CFR	91.7(a):	Civil	aircr aft	airworthiness

This	section	states	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	an airworthy	condition.

Assuming	no	airworthiness	certificate	will	be	required	due	to	relief	requested	from 14	CFR	21	(above),	no	regulatory	standard	exis ts	for	determining	airworthiness. The	equivalent	level	of	safety	will	be	achieved	through	the	implementation	of	the flight	manual	and	maintenance	manual	procedures,	pilot	training/experience,	and analytical	risk	management	for	each	flight.

14	CFR 91.9(b)(2): Civil	Aircraft	Flight	Manual	in	the	Aircraft

This	section	states	that	no	person	shall	operate	a	US	registered	civil	aircraft	for which	a	rotorcraft	flight	manual	is	not	required	by § 21.5	unless	there	is	available	inthe	aircraft	a	current	app roved	rotorcraft	manual	material,	markings,	and	placards, or	any	combination	thereof.

The	Inspire	1/T600	sUAS,	given	its	size	and	configuration	has	no	ability	or	place	to carry	such	a	flight	manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on board,	but	because	there	is	no	room	or	physical	capacity	capability	to	carry	such	an item	on	the	aircraft.		The	equivalent	level	of	safety	will	be	achieved	by	the	operator keeping	the	flight	manual	at	the	ground	control	station,	immediately	accessible	by

t he	operator	during	operations.			Previous	precedence	is	resident	in	Exemptions 8607,	8737,	f8738,	9299,	9299A,	9565,	9565B,	10167,	10167A,	10602,	f32827,	and
10700.

14	CFR	91.103:	Preflight	Action

This	section	requires	each	pilot	in	command	to	take	cert ain	actions	before	flight	to insure	the	safety	of	the	flight.		As	FAA	approved	rotorcraft	flight	manuals	will	not	be provided	for	the	aircraft	an	exemption	is	requested	for	relief.		An	equivalent	level	of safety	will	be	obtained	through	the	operator’s	use of	the	DJI	Inspire	1	Owners manual	along	with	the	petitioner’s/operator’s	safety	plan	outlined	above	(supra). Extensive	flight	planning	under	these	practices	will	provide	the	equivalent	level	of safety.

14	CFR	91.109:	Flight	Instruction

This	section states	that	no	person	shall	operate	a	civil	aircraft	(except	a	manned	free balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has	fully functioning	dual	controls.The	Inspire	1/T600	like	almost	all	sUAS	aircraft		by	their	design	do	no t	have	fully functional	dial	controls.		Flight	control	is	accomplished	through	the	use	of	a	control
box	that	communicates	with	the	aircraft	via	a	2.4	GHz	radio	communications	link. The	FAA	has	approved	exemptions	for	flight	training	without	fully	function al	dual controls	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft. See	exemption	notes	5778K	and	9862A.		The	equivalent	level	of	safety	provided	by the	fact	that	neither	pilot	nor	passengers	will	be	carried	in	the	aircraft	and training would	be	conducted	at	an	FAA	approved	training	site,	operating	under	a	COA.			If training	would	be	conducted	it	should	be	noted	that	the	petitioner	holds	a	Certified Flight	Instructors	Certificate	(3003234	CFI	exp.	07/2017)	for	single	and	multi

en gine	airplane,	and	instrument	airplane.

14	CFR	91.119:	Minimum	Safe Altitudes

This	section	establishes	safe	altitudes	for	operation	of	civil	aircraft.		Section 91.119(d)	allows	rotorcraft	to	be	operated	at	less	than	the	minimums	prescribed, provided	t he	person	operating	the	helicopter	to	be	operated	at	less	than	the minimums	prescribed,	provided	the	person	operating	the	helicopter	complies	with any	route	or	altitudes	prescribed	for	rotorcraft	by	the	FAA.		As	this	exemption	is	for a	sUAS,	that	is	a	roto rcraft	and	the	exemption	requests	authority	to	operate	at altitudes	from	the	surface	to	400’	AGL,	an	exemption	may	be	needed	to	allow	such operations.		As	set	forth	herein,	except	for	the	limited	conditions	stated	in	the	DJI Inspire	1/T600	manual,	the	sUAS will	never	operate	at	an	altitude	higher	than	400’ AGL.		It	will	however	be	operated	in	a	restricted	area	with	a	bounded	security perimeter	where	buildings	and	individuals	will	not	be	exposed	to	operations without	their	pre

- obtained	consent.		This	level	o f	safety	will	be	achieved	utilizing telemetry	from	the	Inspire	1/T600	sent	back	to	the	operator’s	console.		Telemetry includes	the	following	flight	data:	altitude	(AGL),	vertical	and	horizontal	speed, direction	and	distance	from	operator.The	equivalent level	of	safety	will	be	achieved	given	the	size,	weight,	speed,	of	the sUAS	as	well	as	the	location	where	it	will	be	operated	over.		No	flight	will	be	taken without	the	permission	of	the	property	owner	or	local	authorities.		Because	of	this
advance	notice to	the	property	owner,	and	participants,	all	affected	individuals will be	aware	of	the	flight	operations.		Compared	to	flight	operations	with	rotorcraft	or fixed	wing	aircraft	weighing	more	far	more	than	the	maximum	55	pounds	proposed in	this	exemption	he rein	and	the	lack	of	flammable	fuel,	the	risks	involved	we believe	are	far	less	than	those	presently	presented	with	conventional	aircraft	used for	our	stated	purposes.		In	addition,	a	level	of	safety	to	aircraft	operating	in	the	NAS will	be	achieved	throug h	our	flights	being	at	the	lowest	altitude	possible	below	400’ AGL,	and	offering	full	right	of	way	to	approaching	aircraft.

14	CFR	91.121:	Altimeter	Settings

This	section	requires	each	person	operating	an	aircraft	to	maintain	cruising	altitude by	reference	to	an	altimeter	that	is	set	“to	the	elevation	of	the	departure	airport	or an	appropriate	altimeter	setting	available	before	departure.”		As	the	sUAS	may	not have	a	barometric	altimeter,	but	instead	a	GPS	altitude	readout,	an	exemption	may be	needed.		An	equivalent	level	of	safety	will	be	obtained	by	the	operator,	operating the	aUAS	pursuant	to	the manual	and	safety	checklist,	confirming	the	altitude	of	the
tak eoff	site	shown	on	the	GPS	altitude	indicator	before	each	flight.

14	CFR	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions

This	section	prohibits	an	individual	from	beginning	a	“flight	in	an	airplane	under VFR	conditions	unless	(considering	win d	and	forecast	weather	conditions )	there	is enough	fuel	to	fly	to	the	first	point	of	intended	landing,	and	assuming	normal cruising speed

– (1)	During	the	day,	to	fly	after	that	for	at	least	30	minutes.The	battery	power	system	in	the	DJI	Inspire	1/T600 sUAS	provides	the	aircraft	with approximately	25	minutes	of	total	flight	time.	When	the	Inspire	1/T600	battery	is	at 25%	approx.	10	minutes	of	flight	time	is	left.		As	stated	in	our	safety	plan	above,	the
sUAS	will	n ot	be	operated	with	less	than	35%	or	ap prox.	12 minutes	of	flight	time remaining.		The	operator	needs	relief	from	the	30	minute	requirement	stated	in	this section	as	that	time	is	longer	than	the	useful	flight	time	of	the	aircraft	altogether.

14	CFR	91.203(a)	and	(b):	Carrying	Civil	Aircraft Certification	and	Registration

This	section	requires	that	a	person	carry	an	appropriate	airworthiness	certificate that	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or
crew.		The	sUAS has	no	onboard	pilot	or	passenger,	and	no	area	to	stow	these required	papers.

An equivalent level	of	safety	will	be	achieved	by	keeping	these	documents	at	the ground	control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	access	to them,	to	t he	extent	they	are	applicable	to	the	sUAS.		The	FAA	has	issued	numerous exemptions	to	this	regulation.		A representative sample	of	other exceptions includes Exemption	numbers:	9565,	9665,	9789,	9789A,	9797,	9797A,	9816A,	and	10700.

14	CFR	91.405(a),	91.4 07(a)(1),	91.409(a)(2),	91.417(a)(b):	Maintenance Inspections

These	sections	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft inspected	as	prescribed	in	Subpart	E	of	this	part	and	shall	between	required inspections,	except	as	provided in	paragraph	(c)	of	this	section,	have	discrepancies repaired	as	prescribed	in	part	43	of	this	chapter....,”	and	other	shall	inspect	or maintain	the	aircraft	in	compliance	with	Part	43.		Given	that	these	sections	and	Part43	apply	only	to	aircraft	with	an	ai rworthiness	certificate,	these	sections	will	not apply	to	the	petitioner.		Maintenance	will	be	accomplished	by	the	operator	pursuant to	the	DJI	flight	manual	and	operating	handbook.

An	equivalent	level	of	safety	will	be	achieved	because	these physically	s mall	and lightweight small	sUAS’s	are	very	limited	in	size	and	will	carry	a	very	small	payload operating	only	in	restricted	operational	areas	for	limited	periods	of	time.		If mechanical	issues	arise,	the	sUAS	w ill	land	immediately	and	will	be	no	higher	tha n 400’	AGL.		A s provided	in	the	flight	manual,	the	operator	will	ensure	that	the	sUAS	is in	working	order	prior	to	starting	a	flight,	performing	any	required	maintenance beforehand.		Moreover,	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.

Closing

Gary	Buzel	is	committed	to	safe	flight	practices,	while integrating safe	sUAS operations	to	the	National	Airspace	System	(NAS). We	are	co nfident	in	executing commercial	sUAS	operations	that	are	safe,	and	provide	a	service	to	the	public.

Gary	Buzel	is	prepared	to	respond	to	any	concerns	and	I	look	forward	to	working with	the	FAA	on	this	important	exemption.		Please	contact	us	with	any follow

- up questions	or	concerns.

Respectfully	Submitted,

__________________________________________ Gary	Buzel
ATP	Pilot	Cert	#	3003234