* Plea se note, there was a decision in serted in my docket that doesn’t belong there. T his response is

from:

AirCam Photography Tipp on Chandler Weiss 798 Lighthouse #232 Monterey, Ca 93940

This is a follow up to my petition for exemption posted to the public docket on December 2, 2014,

Docket No. FAA

- 2014

- 1006 in your request for more information to comply with the requirements of §11.81 for your consideration.

Specific section or sections of 14 CFR from which I seek relief and the reason I seek relief: Part 21; and §§ 45.23(b); 91.7(a); 91.9(b)(2); 91.103(b); 91.119; 91.121, 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) & (b) o f Title 14, Code of Federal Regulations Part 21 91.203(a) & (b) Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by him, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) subject t o certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333).

45.23 Marking of the aircraft because UA will not have a cabin, cockpit or pi lot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Will mark UAS in the largest possible lettering by placing the word “ experimental ” on its fuselage as required by § 45.29(f) so that anyone assisting him as a spotter will see the markings. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be required and should be granted since they only a pply to aircraft with an airworthiness certificate. However as a safety precaution user will perform a preflight inspection of his UAS before each flight as outlined in his operating documents

and follow manufacture maintenance recommendations as stated in UA user manual. 91.7(a ) prohibits the operation of an aircraft without an airworthiness certificate. There is currently no certificate applicable to this operation, this regulation is inapplicable. 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board his aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station. 91.103(b) The PIC will take all actions including reviewing weather, flight battery requirements, landings, and takeoff distances and aircraft performance data before initiation of flight.Stricter requirements with regard to visib ility and distance from clouds; this is to both keep

the UA from departing the VLOS and to preclude the UA from operating in the NAS. Sun glare will be taken into account. PIC’s and VO’s ability to still see other air traffic, combined
with the PIC’s abili ty to initiate a return

- to

- home sequence, are sufficient mitigations. The

PIC will also account for all relevant site

- specific conditions in his or her preflight procedures.

91.119 Prescribes safe altitudes for the operation of civil aircraft, but that it allows helicopters to be operated at lower altitudes in certain conditions. UAS will not be operated above the altitude of 400 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus “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 of the UAS, an equivalent or higher level of safety will be achieved.

91.121 Altimeter settings is inapplicable since he UAS utilizes electronic GPS with a barometric sensor. Sensor is calibrated before flight and reads AGL altitudes. 91.151 (a) Fuel requirements for flight in VFR conditions, prior relief has been granted for manned

aircraft to operate at less than 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 will land prior to the

man ufacturer’s recommended minimum level of battery power (30%). The operating documents indicate that the low battery level failsafe is triggered when the battery is depleted to a point that may affect the safe return of the aircraft. Users are to return hom e or land the aircraft immediately when these warnings are shown. Pilot ground station will advise user to return the aircraft to the Home Point when low battery warning is triggered. Aircraft will automatically return to home point if no action is taken a fter 10 second countdown. User can cancel the return to home any time. The thresholds for these warnings are automatically determined based on the current aircraft altitude and its distance from home point. Aircraft will land automatically if the current b attery level can only support the aircraft to land to the ground from the current altitude. User can use ground station to control the aircraft during landing process.

How my request will benefit the public as a whole: I would gladly offer my services upo n request and with proper coordination and appropriateness to any official search and rescue or emergency services organization to benefit the public. Agricultural and crop inspection could substantially decrease water usage and increase efficiency in the industry by identifying troubled areas and waste . This would greatly benefit the public as we have been in a water drought on the West Coast for the last three years. Aerial videography for geographical awareness

, agricultural applications, and marketin g has been around for a long time through manned fixed wing aircraft and helicopters. Although they have been operated in an extremely safe manner , my UAS s pose much less risk since the small size and lack of combustible fuel greatly reduces the potential threat to the public. Congress has already proclaimed that it is in the public’s in terest to integrate commercially flown UAS's into the national airspace sy stem, hence the passing of the Reform Act. Granting AirCam Photography’s exempt ion reque st furthers the public interest through academic/visual awareness of the

geog raphical benefits in and around the Monterey Bay area. My light weight UAS is battery powered

and creates no emissions that can harm the environment. The conse quence of my light weight UAScrashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible

fuel and can cause catastrophic devastation to the public. The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture t hrough my battery operated light weight UAS's.

The reasons why the exemption would not adversely affect safety or how the exemption would provide a level of safety at least equal to existing rule:

My, Tippon Chandler Weiss’s , exemption will not adversely aff ect safety. Quite the contrary, for the reasons stated permitting me, Tippon Chandler Weiss

, to log more flight time in FAA controlled airspace

wil l allow me to contribute to the innovatio n and implementation of new and novel , as of yet undiscovered safety protocols for UAS operators.

 I generally operate my UAS below 200 feet AGL (well within the 400 foot permissible ceiling set by the FAA Modern ization and Reform Act of 2012)

 I don’t ope rate within 5 miles of an airport unless prior contact to Air Traffic Control or the airport manager has been made. I determine this distance with GPS using a pilot’s app call ed Foreflight on the Apple Ipad or Iphone.

 I land my UAS prior to manufacturer recommended minimum level of battery power

 I pilot my UAS through remote control by line of sight

 My UAS uses GPS a nd a flight safety feature whereby it returns to a preprogrammed position and then slowly lands if communication with t he remote control pilot is lost

 I actively analyze flight data and other sourc es of information to constantly updat e and enhance safety protocols

 I only operate in reasonably safe environment th at are strictly controlled, are away from power lines, elevated lights, airport s and actively p opulated areas

 I conduct extensive pre

- flight inspections an d protocol, during which safety carries primary importance

 I always obtain all necessary permi ssions prior to operation; and,

 I have procedures in place to abort flights in the event of safety br eaches or potential danger.
My, Tippon Chandler Weiss’s , safety protocols (see attached) 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 syst em, helicopters are the pr imary means of aerial video and photography for community awareness , inspections, crop management, and real estate. While the safety record of such helicopters is remarkably astounding, it is far safer to operate a battery powere d UAS. First, the 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. Second, there is no fuel on board a UAS and thus the potential for fire or ex plosions is greatly diminished. Third, the small size and extreme maneuv erability of my UAS allow me to remotely pilot away from and av oid hazards quickly and safely. Accordingly, my UAS has been experimentally operated for familiarization/competency and will conti nue to operate at and above current safety levels.

Additional Information:The bulk of our aerial operations will be using the DJI Phantom 2 with Gimbal (3 pounds) and the DJI

Inspire 1 (6.5 pounds) Using the same safety protocols as outlined and found in our Safety Protocol Manual (Separate document) for the DJI Phantom 2 and DJI Inspire 1 and an additional camera operator /observer , we would like to have the option of employing the DJI S900, a six (6) rot or multirotor UAS with GH4 Gimbal

or similar vari ants (16.5 pounds). We feel we can operate all 3 UAS platforms with utmost safety without putting the general public or manned aircraft at risk. As not ed in exe mption 11138 for Douglas Trudeau, Realtor, the minimum separat ion between the public a nd his operations is 150 feet for his 3 pound DJI

Phantom 2. W e feel this is a safe minim um distance but if it is deemed that it needs to be larger, we

would like to at lea st have the option of operating our DJI Phantom 2 at 150 feet or greater and the larger separation distance to apply to our DJI Inspire and /or DJI S900.

10 Additional d ocuments submi tted as proprietary information.

Sincerely, Tippon Chandler Weiss

AirCam Photography