20

- B Ensanche Ramirez St., San German, PR 00683 Tel. 939

- 630

- 9556 email: richard@segurosenpr.com

July 24, 2015

TO: U.S. DEPARTMENT OF TRANSPORTATION
DOCKET MANAGEMENT SYSTEM
1200 New Jersey Avenue SE Washington, DC 20590

FROM: RICHARD L. DUNNAM
FAA PRIVATE PILOT CERTIFICATE 3328805
20

- B Ensanche Ramirez St. San German, PR 00683
Tel. 939

- 630

- 9556
ri chard@segurosenpr.com

RE: Request for Exemption Per PL 112

- 95 §333 from 14 CFR 61.113(a) and (b), 14 CFR 91.103,
14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b)

These documents have been enclosed as attachments to provide additional reference of safety,

maintenance and use of sUAV under consideration for this petition ’ s request for exemption of above :

 DJI Phantom 3 Safety Guidelines

 DJI Phantom 3 User Manual

Dear Sir or Madam:

This document serves as a petition and request for exemption of the above cited section of Title 14 CFR
f or myself , Richard L. Dunnam , hereinafter referred to as “ the petitioner ” , for sole purposes of conducting commercial aerial photography, videography, and survey operations using a small Unmanned Aircraft System (sUAS) in areas that could possibly fall under F AA controlled airspace.

This petition provides necessary information to justify an exemption from the above referenced Federal Aviation Regulations.



### THE s UAS

The petitioner is the sole owner and sole pilot in command (PIC) of a DJI Phantom 3 Professional
multi

- rotor / quadcopter with 4 carbon fiber propellers, onboard camera, gimbal and on

- board flight control systems that uses GPS and ground movement for stabilization purposes , as well as manual input control systems, such as those found in remote control (RC) units. The Phantom 3 is ope rated by way of RC in the 2.4 gigahertz s pectrum.20

- B Ensanche Ramirez St., San German, PR 00683 Tel. 939

- 630

- 9556 email: richard@segurosenpr.com

U.S. D OT DOCKET SYSTEM
PAGE 2 JULY 24, 2015

The Phantom 3 has a built

- in fu nctionality that can limit the height above ground level ( AGL ),
limit the distance between said aircr aft and PI C, therefore restricting its operation under Class B, C, and D airspace. The aircraft also provides the ability to “ return to home ” (RTH) towa rd the PIC
and land if connection to the RC is lost for more than 3 seconds.

The aircraft weighs in at 1,280 gram s (2.82 lbs.) while carrying battery and camera gimbal. It has a maximum spee d of 16 meters per second at 0 wind (just under 30 knots). It is powered by Lithium Polymer battery which supplies electric power to the 4 on

- board brushless motors.

You may refer to the enclosed attached documents pertaining the DJI Phantom 3 User Manual, for more specific details.

It is warranted by petitioner that no changes to th e aircraft will be made to such manufacturer ’ s specifications

.


### THE UAV PILOT IN COMMAND (PIC)

The petitioner will be acting as sole PIC of the DJI Phantom 3 Professional aircraft r eferenced herein. The petitioner is an experienced sUAS pilot sinc e 2012 and has been PIC for the Phantom

3 without incident. For practical, safety and operational compliance, a visual observer (VO) will be present at all times during flight. Also, the petitioner holds a n FAA Private Pilot Certifi cate with

3 rd Class Medical ( Richard Dunnam

- Certificate number 3328805) and was previous owner of

Cessna 172M N

- 9397H, with experience in light maintenance and safety features of said aircraft
type. U.S. Passport Card Number: C07533578

The petitioner is experienced in risk manageme nt, loss prevention surveys , insurance claims investigator

, surveyor, educator, speaker, and photography for more than 30 years , which provides and extra level of safety a nd preventive attitudes to ensure the safety of people and
property.



### THE OPERATIONS REVIEW

The sUAS operations scope will be to provide a erial phot os, videos, and survey ing services to the general public sectors, governmental, resi dential or comm ercial, and particularly pertaining to real estate properties, general events, activities and surveys

.

Operations unde r this exemption request i s accepted by the petitioner to program or operate aircraft to prevent it from flyin g 400 feet or more AGL or 1,500 feet away from PIC.20

- B Ensanche Ramirez St., San German, PR 00683 Tel. 939

- 630

- 9556 email: richard@segurosenpr.com

U.S. D OT DOCKET SYSTEM
PAGE 3 JULY 24, 2015

Before every operation and therefore takeoff, P IC and VO will review the aircraft ’ s checklists ( as found under manufacturer provided documentations, as well as containe d herein the attached
documents ) and survey area to determine if weather / wind / cloud conditions are suitable for flight and to determine emergency landing sites. All nearby persons will be dully notified and

ma de aware of any flight operations . Flights will not take place over densely populated areas n or private property without owner ’ s or occupant ’ s permission. After landing, flight operations will not be considered complete, unless a thorough physical insp ection of all aircraft parts, batteries
and camera is finalized to determine if any maintenance is needed.

In comparison with manned fli ghts, sUAS are less dangerous, hence would not affect safety adversely. We take into account the following, which justifies our need for exemption of the
referenced FAR ’ s sections and rulings :

 The aircraf t carries and uses no explosive materials or combustible liquid fuels of any kind

.

 The sUAV

, less than 3 lbs. of total aircraft weight with battery and camera gimbal , would cause minimal damage in th e event of flight failure.

 The sUAV operational properties will allow to operate the same under a defined and controlled area for takeoff, fli ght and la nding.

 Takeoff s , flight s and landings will be restricted to small area where all nearby people may and can be aware of flight operations in progress.

 All flights by PIC will begin and remain more than 5 mile radius of any airport , unless approved by Flight Standards Services, Ground / T ower Controls.

 All flights will b e maintained with visual line of sight (VLOS) of both, PIC and VO

 Visual and verbal contact will be maintained at all times of flight operations between PIC and VO to detect and avoid possible midair hazards, such as trees, foliage, overhead transmission lines, towers, birds, animals or other objects

.

All aspects of operat ions will be conducted with the utmost consideration for safety . Preflight

, flight, and post flight safety assessment continuity and the inherently reduced risk of flying a

sUAS ( when compared to traditional manned aircraft for video, photo and surveys) the petitioner
will be able to provide a greater level of safety.20

- B Ensanche Ramirez St., San German, PR 00683 Tel. 939

- 630

- 9556 email: richard@segurosenpr.com

U.S. D OT DOCKET SYSTEM
PAGE 4 JULY 24, 2015



### THE BENEFIT TO PUBLIC INTEREST

By the FAA granting this exemption, it will provide a practical and economical benefit to
consumers i n general, in the petitioner ’ s territory of operation within the Commonwealth of
Puerto Rico , USA

. By prov iding other alternatives to traditional forms of aerial videography, photography, and surveys , we all can benefit economically and risk wise.

These key aerial sUAV characteristics make these services more accessible to smaller businesses, small and family owned agricultural operations, surveying hom e owner s and condo associations

, just to name a few as examples. All this, in turn increases public benefit as a whole.



### IN CONCLUSION

The petitioner shall satisfy all criteria as established in Section 333 of the Reform Act of 2012, including : size, weight, speed, flight within VLOS, distance from PIC, distance from airports, operational capabilities, preventive and safety maintenance, and benefit to the public in general.

Also

, in accordance with F AA ’ s announcement of March 23 rd , 2015, the petitioner will apply for a Certificate of Waiver or Authorization for any and all flights above 200 feet AGL.

These qualifications justify granting the petitioner, Richard L. Dunnam, with an exemption to the

st ated sections of Title 14 CFR. In addition, the requests of this petition are very similar and no
different to nu merous other businesses (corporations, LLC ’ s or individuals) , all of whom have
received Section 333 exemptio ns for use of comparable aircraft for similar operations.

I appreciate all your efforts and should you require contacting me, the petitioner, you may do so

at e

- mail: richard@segurosenpr.com or phone number 939

- 630

- 9556

. Thank you very much for

your cons ideration.

Best Regards,

Richard L. Dunnam The petitioner