Christopher	S.	Hebert 2308	Century	Park	Blvd. Austin,	TX		78727

512

- 388

- 3745	(Home)

email: chris.s.hebert @gmail.com

U.S.	Department	of	Transportation,	Docket Operations West	Building	Ground	Floor,	Room	w12

- 140 1200	New	Jersey	Avenue,	SE.,	Washington,	DC	20590

Dear	Recipient,

In	acco rdance	with	the	FAA’s	Guidelines	for	Submitting	a	Petition	for	Exemption

under	section	333	of	the	FAA	Modernization	and	Reform Act	of	2012,	I Christopher	Hebert

, referred	to	as	the	petitioner,	kindly	request	exemption	from	the	following	sections	of Title	14,	Cod e	of	Federal	Regulations	§§

14	C.F.R.	61.113(a)

14	C.F.R.	61.113(b)

14	C.F.R.	91.119(c)

14	C.F.R.	91.121

14	C.F.R.	91.151(a)

14	C.F.R.	91.405(a)

14	C.F.R.	91.407(a)(1)

14	C.F.R.	91.409	(a)(1)

14	C.F.R.	91.409(a)(2)

14	C.F.R.	91.417(a)	&	(b)

I	the	Petitioner	seek	relief	from	the	listed	regulations	in	order	to	operate	small unmanned aircraft	systems	(UAS)	commercially	in	a irspace	regulated	by	the	Federal Aviation Administration	(FAA)	for	the	purposes	of	aerial	photogra phy, cinematography,	videography	and other	aerial	operations	that	can	be	performed	safely and	more	cost	effectively	with	the	use	of

small	UAS	at	low	altitude	within	the	U.S. national	airspace	system	as	compared	to	a	manned aircraft.	Safe	UAS	operations c onducted	within	FAA	guidelines	will	support	local	business	andcreate	positive awareness	in	the	community	by	providing	UAS	a lternatives	to	previous	methods

of larger,	more	dangerous	aircrafts.	Compensated	tasks	will	be	conducted	only	at	the request	of

a nd	with	authorization	and	permission	of	clients	or	their	authorized	agents in	compliance	with privacy	Laws	and	FAA	Regulations.	In	addition,	only	the authorized	individual/Operator,

Christo p her	Hebert will	conduct	UAS	flights	within	and under	the	conditions	outline d	herein	or as	may	be	established	by	the	FAA	as	required by	Section	333.

The	FARs

I,	t he	petitioner	seek	exemption	from	the	above	mentioned	FARs	for	the	following r easons:

61.113(a)	&	(b)

The	petitioner	requests	relief	in	order	to	facilitate	the	ut ilization	of	an	experienced UAS	operator	with	the	addition	of	a	trained	observer.	All	pre

- flight	inspection, maintenance	and flight	logs	will	be	saved	and	made	available	to	the	FAA	and Secretary	of	Transportation	(SoT)	for review;	with	the	purpose	of	sa fely	integrating civil	UAS	operation	in	the	National Airspace System.	The	petitioner	will	conduct flights	as	the	authorized	UAS	Operator.	The	UA	controlled by	the	Operator	will perform	at	altitudes	well	below	the	per missible	limits	for	other	civil aircrafts, eliminating	the risk	to	other	aircrafts.

91.119(c)

As	discussed	in	Exemption	11138	(DOUGLASTRUDEAU),	operations	conducted closer	than	500

f eet	to	the	ground	may	require	that	the	UAS	be	operated	closer	than 500	feet	to	essential persons,	or	objects	that	would	not	be possible	without	additional relief.	The	petitioner	requests modification,	waiver	or	exemption	and	clarification concerning	the	terms	“congested	areas” and	“densely	populated”.	The	petitioner requests	waiver	for	this	condition	to	allow	reasonable and	respo nsible	operations	in areas	of	subdivisions	and	neighborhoods	if	required.	The petitioner	will	primarily operate	th e	UAS	between	ground	level	and	4 00	feet.	The	UAS	will	be operated	over designated	properties	with	the	consent	of	the	local	municipality	or their designated agent	and	while	maintaining	a	safe	distance	from	persons.	The	petitioner	will compile flight	data	from	the	logs.	This	data	may	assist	the	FAA	in	development	of	regulations

f or	commercial	operations	in	low

- risk,	controlled	environments.

91 .121

As	discussed	in	Exemption	11138	(DOUGLASTRUDEAU)	is	inapplicable	since	the UAS	does	not

have	an	altimeter	and	instead	utilizes	electronic	GPS	with	a	barometric sensor	for	altitude information.	Altitude	information	is	generated	by	the	UA	on	board compu ting	system,	its	then received	and	displayed	at	the	operators	ground	station.91.151(a)

As	discussed	in	Exemption	11136	(ADVANCEDAVIATION	SOLUTIONS	LLC) prior	relief	has	been granted	for	manned	aircraft	to	operate	at	less	than	the	prescribed minimums ,	including Exemption	Nos.	2689,	5745,	and	10650.	In	addition,	similar UAS	specific	relief	has	been	granted in	Exemption	Nos.	8811,	10808,	and	10673	for daytime,	VFR	conditions.	The	UAS	provides battery	power	remaining	in	percent	to the	PIC.	The	UA	b a tteries	pro vide	approximately	25 minutes	of	powered	flight. Information	provided	in	the	operating	documents	discusses procedures	regarding remaining	battery	power	management.	Those	documents	contain	a

condition	in	which the	PIC	will	initiate	a	landing	procedure	when	battery	remaining	reaches	a specified level.	Given	the	limitations	on	proposed	operations	and	the	location	of	those proposed operations,	The	FAA	found	that	a	reduced	minimum	power	reserve	for	flight	in

D ayt ime VFR	conditions	was	reasonable.

91.405(a);	91.407(a)(1);	91.409	(a)(1)	&	(2);	91.417(a)	&	(b)

As	discussed	in	Exemption	11138	(DOUGLASTRUDEAU),	The	petitioner	proposes to	inspect	and ensure	that	the	UAS	is	in	a	condition	for	safe	flight	in	accordance with the	operating documents.	The	FAA	found	that	adherence	to	the	petitioner’s	operating documents	and	the conditions	and	limitations	specified,	describing	the	requirements for	maintenance,	inspection,

and	record

- keeping,	were	sufficient	to	ensure	that	sa fety would	not	be	adversely	affected.

Areas	of	interests	for	UAS	commercial	use

Aerial	video	and	or	photography	for	real	estate,	architecture,	agriculture,	land surveying, engineering,	television,	cinematography,	and	news	media.	Aerial inspections	and or photography	of	residential	or	commercial	structures,	utility infrastructures	including	but	not limited	to	electrical	power	lines,	wind	turbines	and cell	towers.	In	addition,	live	streaming	aerial

video	in	efforts	assist	in	search	and rescue	operatio ns	ONLY	at	the	legal	authorization	of	local authorities	or	government.

The	UAS

The	petitioner	seeks	exemption	to	operate a UA	Multifunctional	Quad

- rotor	Systems	by

3DR ( Solo )	for	compensation	or	hire within	the	N ational Airspace	System.	The 3DR	Solo	is	a highly successful	consumer	grade	small	rotor	crafts	in	the	quadcopter	configuration.	They	are vertical	takeoff	and	landing	(VTOL)	UAS	with	a	Ground	Control	Station	(GCS) utilizing	an

electron ic	tablet or	cellular	smart	phone .	The system contain s internal	measuring	units (IMU) with	integrated	barometric	sensors	augmented	with	global	positioning	systems	(GPS) to maintain	their	geospatial	orientation	and	position.	Real	time	video	control	station allows	the operator	and/or	PIC	to	monitor	battery	level, GPS	signal	strength,	altitude, distance	from	PIC, camera	imagery,	and	control	camera	angle.	Integrated	failsafe mode	Return	to	Home	aid	andassist	operations	for	e ither	loss	of	RC	or	GPS	signal. The onboard	flight	controllers	will	warn	the pilot	via	telemetry	and	external	lighting cues	before	reac hing	a	low battery	state.	The	UAS	has the	capability	to	abort flights	and	return	to	home	safely	in	case	of	any	unpredicted	obstacles	or emergencies.

3DR	Solo

Height: 10 in	/	25cm

Wid th	(motor	to	motor):		18in	/	26cm Weight (with	battery	installed): 3.3 0lb /	15kg

Intell igent	Flight	Battery:	5200mAh	25 min	Flight Time Max	Flight	Speed:		5 5mph Operating	Frequency:	2.4GHz	ISM Key Features:

Live	real

- time	flight	data Intelligent	Orientation	Control	( IOC),	GPS,	and	Return	to	home	failsafe

Self

- tightening Propellers Dynamic	home	point	orientation Intelligent	Flight	Battery	includes	capacity	data,	over	charge/discharge	prote ction, maintenance

data.Risk	Mitigation

Aerial	Safety	is	of	the	utmost	concern.	I	the	petitioner	have	reviewed	FAA exemptions

reference’s	1

- 3	Conditions	and	Limitations	section	and	believes	that	the procedures	specified therein	are	reasonable	and	will	be	utilized	in	order	to	manage and	mitigate	ris k	and	ensure public	safety.	A	preflight	checklist	is	being	developed and	employed	to	ensure	that	the	UA

airworthiness	and	will	be	verified	before	each launch.	Airw orthiness	will	be	maintained	by performance	of	routine	inspections before	each	flight,	maint aining	flight	and	maintenance	logs.

These	documents	will	be made	available	upon	request	to	ass ist	in	future	implementation	of safety	standards	and regulations.	The	petitioner	will	only operate	the	UAS	over	designated properties	with the	clients	consent.	F light	plans	will	be	predetermined	to	limit	the	UASs	flight

time and	limit	safety	concerns.	The	petitioner	will	take	into	account	distance	from	persons and potential	flight	obstacles	prior	to	operating	the	UAS.	UAS	operations	will	always be	within	VLOS

of	the PIC	and	the	observer.	The	petitioner/Operator	will	carry suitable	insurance	for	the protection	of	the	Operator	and	the	Public	thus	providing positive	and	responsible	UAS operations	in	the	community.

Developing	Flight	Check	List

On	hand 3DR	Solo official	m anuals	and	procedures Reference	B4UFLY	Smartphone App Optimal	weather	conditions	have	been	verified Location	scouting	including	landing	and	takeoff	distance Establish	reasonable	low	altitudes	to	ensure	safety	of	civil	aircrafts

Obtai n	consent	of	all	persons	involved	in	filming	including	land	and	property	owners Visual	Inspection	of	aircraft Prepare	flight	logs Flight	battery	and	transmitter	battery	at	full	charge Propellers	are	in	proper	airworthy	conditions	and	are	securely	locked	and	mo unted Perform	sensor	and	compass	calibration

3DR Ground	Station	activated Clear	uninterrupted	communication	between	UAS	and	remote Visually	inspect	and	ensure	all	motors	are	run ning	properly	and	rotate	evenly Ascend	10ft	for	control	inspections:	Forward ,	Back,	Left,	Right,	Hover Visually	inspect	for	controlled	flight	performance along	with	ground	station	data Flights	will	be	operated	within	line	of	s ight	of	a	pilot	and/or	observer Maximum	flight	time	for	each	operational	flight	will	be	no	more	than	3 0	minutes Flights	will	be	terminated	at	no	less	than	25%	battery	power	reserve	should	that	occur prior	to

the 30

- minute limit Flights	will	be	operated	at	an	altitude	below	400	feet AGL,	and	not	more	than	200	feet above	an elevated	platform	from	which	fi lming	is	planned Upon	completion	of	flight	operations	perform	visual	inspection Record	all	flight	data	into	the	Flight	Logs Perform	regular	scheduled	maintenancePublic	interest

Choice	of	UAS	over	a	manned	aircraft	would	enhance	safety	and	reduce	th e environmental impact	as	compared	to	similar	operations	conducted	with	manned aircraft	of	greater proportions,	carrying	a	crew	and	flammable	fuel.	Additionally,	the use	of	the	UAS	in	order	to facilitate	commerce	could	lead	to	economic	growth. Operations	for	this	petition	will	enable service	for	property	owners	or	their	designee s seeking	an	enhanced	perspective	for characteristics,	amenities,	and	benefits	of	their desired	photographic	subjects	that	cannot	be displayed	through	ground	level videogr aphy/photography.	Crop	surveying	applications	could

lead	to	decreased	use	of pesticides	and	fertilizer	and	conservation	of	water	as	well	as	increased crop	yields	and decreased	costs.	Aerial	surveying	and	in spections	can	increase	planning efficiency, imp rove	resource	estimations,	and	reduce	risks	to	personnel	and	property.	The petitioner	will	provide	clients	with	photographic	data	for	these	purposes	on	a	‘for	hire’ basis acting	as	an	independent	contractor.	Flight	data	including	UA	flight	time, Control	Uni t	operation time,	incident,	accident,	and	details	concerning	any	deviations from	normal	operations	will	be available	upon	request	for	use	in	collecting	data regarding the use	of	UAS	as	part	of	these applications.

Conclusion

The	petitioner	is	requesting	th is	exemption	for	the purposes	of	aerial	photography, cinematography,	and	videography.	The	petitioner	wishes	to	provide	safe	and	reliable services for	businesses	such	as	but	not	limited	to,	real	estate,	architecture,	agriculture, land	surveying, engineerin g,	television,	cinematography,	and	news	gathering.	By providing	safe	deployments and	cost	effective	operations	through	UAS	the	petitioner offering	a	much	needed	and	desired service	in	the	community.	The	petitioner	can ensure	adherence	to	standards	and	p rotocols	and can	develop	and	refine	generally applicable	safety	guidelines	and	processes.	The	primary purpose	of	seeking	this exemption	is	to	obtain	the	capability	to	offer	UAS	services	while remaining	in compliance	with	FAA	regulations.	The	petitioner	ha s over 3 years	of	experience	in

the UAS	and	radio	control	model	aircraft	hobbies	and	wishes	to	move	forward	in	this ever growing	industry.

Respectfully	Submitted,

Christopher	Hebert