### Chad Tr aywick, Real Estate Photo & Videographer Jackson, MS / Tyler, TX

Section 333 Exemption Petiti on FAA

- 2007

- 0001

January, 1st 2016

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

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a ) (1); 91.409(a) (2); 91.417(a)&(b)

Appendix A

– Phantom 3 Professional User Manual

Appendix B

– Mississippi & Texas area maps

Dear Sir or Madam,

I, Chad Traywick, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Chad Traywick, an owner and operator of

sm all unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Chad Traywick, may operate my small ultra

- light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Adm inistration (“FAA”). As described herein I, Chad Traywick, am a Real

- estate Photographer & Videographer within the State of Mississippi & Texas; experienced in flying hobby helicopters and Airplanes for 25 years for recreational purposes. I have added a ho bby grade quad

- copter1 UAS to my i nventory with intent for aerial videography and cinematography to enhance academic community awareness for those individuals and companies unfamiliar with the geographical layout of the land of Mississippi and Texas, and augme nt real estate listing videos; following exemption and approval by the FAA. There by enhancing their academic research experience for the Mississippi & Texas area.

I have flown small RC electric helicopters & Airplanes for over ten (25) years without inci dent. Committed to safety with each flight my, Chad Traywick, exemption request would permit operation of ultra

- light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly co ntrolled and limited airspace p redetermine d in areas away from general public, airports, heliports and vehicular traffic for community videos, and within property bound aries for individual
homeowner & land real estate listing videos/photos. Currently, similar lightweight, remote controlled
UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I, Chad Traywick, will continue to strictly comply with safety and maintenance procedures included in all applicable UAS manufacturer’s instructions and operating manuals to avoid and prevent public hazard, as wel l as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's specific to real estate video and photography usage as I,Chad Traywick, record flight data and other information gained through permitted f light operations to share with the FAA through any required FAA reports to assist with future protocol and safety regulation.

Granting my, Chad Traywick’s, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use o f UAS's for real estate/Realtor purposes. Further I, Chad Traywick, will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Chad Traywick, respectfully request th e grant of an exemption allowing me to operate ultra

- light weight, remote controlled UAS’s for academic community awareness to benefit/stimulate attraction to the Idaho area and to enhance real estate listing videos for homeowners who cannot afford expensi ve manned aircraft for the same purpose. Both of which will promote local economic growth through increased employment and increased tax base. Both with public safety in mind by keeping heavier manned aircraft containing combustible fuel that that poses po tential public
hazard.

I. Contact Information:

Chad Traywick, Real Estate Photo & Videographer 104 Faith Way Brandon, MS 39042

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Chad Traywick Requests Exemption are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

III. The Extent of relief Chad Traywick seeks and the Reason He Seeks Such Relief:I, Chad Traywick, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent me, Chad Traywick, contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My, Chad Traywick’s, ultra

- light weight UAS meets the def inition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra

- light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra

- light weight UAS prior to the time period by which the R eform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate related UAS aerial video and photography. The Ref orm Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflects in favor of an exemption for me, Chad Traywick. My UAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal.

I, Chad Traywick, consider safety as foremost with each flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS
mode that a llows my UAS to hover in place or return to home when radio controls are released. With three modes to choose from, I utilize the Loiter Mode for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and haza rd. When pilot communication is lost UAS is designed slowly descend to point of takeoff. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me , as the remote control pilot, u tilizing battery power rather than combustible fuels, fligh ts generally last between three (3) to seven (7) minutes, with an altitude under one hundred fifty (150) feet.

I, Chad Traywick, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is fi fteen (15) to twenty

- five (25) minutes as tested. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash that could create haz ard to the public/property/manned aircraft, and have no desire to lose aninvestment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of th is specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate sk ills and response reflex time a ll for the sake of safety.

I, Chad Traywick , am extremely cautious in operating of my UAS/ultra

- light weight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated s afety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. Chad Traywick’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general publ ic or national security.

IV. How Chad Traywick’s Request Will Benefit the Public as a Whole:

Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videogr aphy is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense, d epriving non

- luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the pub lic through potential catastrophic crash that the communit y has experienced in the past, each resulting in loss of life, e ach with combustible fuel that exploded and burned on impact. Police helicopters have made emergency hard landings within city limits. My, Chad Traywick’s, UAS pose no such threat since size and lack of combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's
into the nationa l airspace system, hence the passing of the Reform Act. Granting my, Chad Traywick’s, exemption request furthers the public interest through academic/visual awareness of the geographical
benefits i n and around the Idaho area. My ultra

- light weight UAS i s battery powered and creates no emissions that can harm the environment. The consequence of my ultra

- light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can

cause catastro phic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra

- light weight UAS's. Permitting me, Chad Traywick, to immediately fly wi thin national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the community for companies looking to relocate
or build in the Idaho area as well as Individuals looking to relocate for career advancement through
academ ic and geographical awareness, b oth of which serve as a stimulus to the community.

V. Reasons Why Chad Traywick’s Exemption Will Not Adversely Affect Safety or How the Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:My, Chad Traywick’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Chad Traywick, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for Realtors that can be embraced by the NAR6 , AAR7 , and TAR8 for development in cooperation with the FAA. In addition I, Chad Traywick, submit the following representations of enhancements to current aerial videography and photography for real

estate:

1. My UAS weighs less than 5 pounds complete

. 2. I only operate my UAS below 200 fe et (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012);
3. M y UAS only operate for 20

- 25 minutes per flight; I land my UAS prior to manufacturer recommended minimum level of battery power; I pilot my UAS throu gh remote control only by line of sight;
4. My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;
5. I actively analyze flight data and other sources of information to constan tly update and enhance safety protocols;
6. I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive

pre

- flight inspections and protoc ol, during which safety carries primary importance;
7. I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger.

My, Chad Traywick’s, safety proto cols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community aw areness and real estate. While the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra

- light weight UAS.

1. T he potential loss of life is diminished because UAS's carry no people on board and I only operate my UAS in specific ar eas away from mass populations.
2. T here is no fuel on board a UAS and thus the potential for fire or explosions is greatly
diminished.
3. T he small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely.

Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS
need not be so close to the objects they are focused on through the technology and use of post editing

so ftware allowing pan and zoom.Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above cu rrent safety levels.

VI. A Summary the FAA May P ublish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Cert ificates, Manuals and the Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Chad Traywick’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safe ty pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, Chad Traywick ’s, current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requir es an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineat ing areas of where safety can be defined. 10 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning sy stems with a bar ometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reason s described above. The equivalent level of safety will be achieved by maintaining any such required certifications and regi strations by me, Chad Traywick.

B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications.

My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the w ord “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738,
10 167, 10167A and 10700.C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I, Chad Traywick, can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the risk level s inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Chad Traywick, to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

D . 14 C.F.R. 91.119: Minimum Safe Altitudes

. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. I, Chad Traywick, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed o f my UAS, an equivalent or higher level of safety will be achieved.

E . 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 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. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will
not, therefore, apply to my, Chad Traywick’s, UAS. However, as a safety pr ecaution I inspect my UAS before and after each flight.

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my Chad Traywick’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation perm it the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91 .7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.In summary, Chad Trayw ick seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a);

14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R.

§ 91. 121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14

C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§

91.417 (a) & (b) to commercially operate my, Chad Traywick’s, small unm anned vehicle/lightweight unmanned aircraft vehicle in community awareness and real estate operations, and to develop economic platforms for real estate inspections to enhance the experien ce of those seeking to relocate

. Current ly, area awareness and real estate aerial videography/photography relies primarily on the use of larger aircraf t running on combustible fuel, p osing potential risk to the public. Granting my, Chad Traywick’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS

c raft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established air fields. I, Chad Traywick, have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds currently accepted means and met hods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, Chad Traywick’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Chad Traywick’s, operation of my UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of s afety as that achieved under current FARs. Accordingly I, Chad Traywick, respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public a t large.

Respectfully submitted,

Chad Traywick, Real Estate Photo & Videographer Brandon , MS / Tyler, TX 104 Faith Way Brandon, MS 39042