### Petition for exemption / rulemaking

This is an exemption request pursuant to FMRA Section 333 and Part 1 1 of the FA A Reform Act of 2012 for S trategic Designs. The proposed exemption, if granted, would allow S trategic Designs to conduct commercial operations of small unmanned aircraf t systems (“UAS”) meeting or exceeding all of the operational and safety requirement s Congress has set forth in Section 333. Petit ioner is an aerial service and technology comp any that plans to exploit the cap abilities of Unmanned Aerial Systems to of fer a multitude of services, including:

- Aerial surveying / inspections
- Remote sensing
- Te lecommunications
- Agriculture
- Aerial filmmaking and photography
- Energy systems inspections and asset management / wind turbine inspection

- Construction site inspections and monitoring
- Wi ldlife and forestry monitoring

- Educational and research operations
- Pipeline / cell tower inspecti ons **Pilot in Command (PIC)** The pilot in command will be the owner of S trategic Designs, Mr . Brian Gaudet. Mr . Gaudet received his airman’ s Private Pilot Certificate in 1977, number 3638364 and holds a current F AA
- issued 3rd class airman medical certificat e. Mr . Gaudet has logged over 150 hours in single engine aircraf

t. Mr . Gaudet is also currently 1/5 owner of a Cessna Cardinal 177B which he flies regularly

. Petitioner will comply with the applicable procedures and requirement s st ated in § 91.103. S pec ifically , the PIC will t ake all actions including reviewing weather, flight battery requirement s, aircraf t performance data, and landing and takeoff distances before initiation of a flight. The PIC will also account for all relevant site
- specific condition s in their preflight procedures. **Cont act information:**  Brian Gaudet 39 T if fany Cir

. Millbury, MA

01527 bgflyer@icloud.com 508
- 754
- 5664**Petition Exemption Summary :** 

**The specific section or sections of 14 CFR from which y ou seek an**  **exemption;** Petition for Exemption under Sec 333 Regulations from which the exemption is requested:

- 14 C.F .R. Part 21 (H)

- 14 C.F .R. 61

- 14 C.F .R. 91.103(b)(2)

- 14 C.F .R. 91.105

- 14 C.F .R. 91.109

- 14 C.F .R. 91.1 19

- 14 C.F .R. 91.121

- 14 C.F .R. 91.151

- 14 C.F .R. 91.405

- 14 C.F .R. 91.407

- 14 C.F .R. 91.409

- 14 C.F .R. 91.417

**The extent of relief y ou seek and the reason y**  **ou seek the relief;** Sec 333 prohibits the use of a UAS for commercial purposes on private property

. I am a member of the Academy of Model Aeronautics. I am p etitioning for an exemption to provide a commercial service to private land owners and companies who wish to obt ain an d capture Aerial photos and videos of said property for purposes including real est ate listings, agriculture monitoring, insurance property claims, inspections, and monitoring structures (roofs) and for use as a marketing tool for businesses. I would like to be able to accept payment for these services therefore making this a commercial use of a UAS. Also, I request a grant of exemption to use any aircraf t identified on the List of Approved UAS under Section 333 at regulatory docket F AA
- 2007
- 3330 at www .re gulations.gov , when weighing less than 55 pounds including p ayload. Proposed operations of any aircraf t not on the list currently posted to the above docket will require a new petition or a petition to amend this exemption.**How y our request would benefit**  **the public as a whole;**

My request benefit s the public as a whole by providing an opportunity for small business owners, real estate agent s, and others who wish to document their land or property, to t ake advant age of the technology that now exists in the form of UAS’s and allows them to do so using an experienced and certified RC Pilot in Command that underst ands how to safely operate such technology

. **Reasons why**

**the exemption would not adversely affect safety** 

**, or how the exemption would provide a level**  **of safety at least equal to the existing rule;**  I am an F

AA licensed Private Pilot, a member of the A MA a nd therefore underst anding the import ance of dif ferent uses and safety concerns regarding FA A regulated airsp ace, I would be a good candidate for ex emption of Sec 333 while not putting Air Safety in any accelerated risk. The specific UAS (DJI Inspire 1 whose Operating Manual is Included in my petition) The DJI Inspire 1 UA V includes GPS navigation and many more safety systems outlined in the reference d manual. When flying for this commercial purpose I would be flying at a maximum altitude of 400 feet with the majority of flight operating at less than 200 feet. Flight s would be mostly vertical f or the purposes of t aking photos / video, decreasing the r isk of any interference to other aircraf t and persons on the ground or in the area. My general knowledge of the aviation safety systems implemented by the F

AA would be used to ensure that safety would not be affected by my operations. I would not be flying near disaster areas, sporting events, or high traf

fic areas including airport s, and I would p ay attention to all NOT AMS. **I Intend to follow these suggested safety regulations;**  • Always keep aircraft in sight and under control. • Always keep people and pets at least 35 feet (10 meters) away when the battery is connected. • Keep children out of the vicinity of this product at all times. • Always use fully charged batteries. • Always keep transmitter powered on while aircraf t is powered. • Always remov e batteries before disassembly

. • Always keep moving p arts clean. • Always keep p arts dry

. • Always let p arts cool after use before touching. • Always remove batteries af ter use. • Always have a first aid kit with you. • Always have a n appropriate fire extinguisher with you.• Never operate aircraf t with damaged wiring. • Never touch moving p arts. • Follow all safety recommendations det ailed by the manufacturer (DJI).
**A summary** 

**we can publish in the Federal Register Federal Regist er**  **—** I, Brian Gaudet am seeking an exemption of the FAA ’s Sec 333 rules that does not allow the use of an Unmanned Aircraft to be used for Commercial purposes in regards to National Airspace Safety. I am p etitioning for an exemption to provide a commerci al service to private land owners and companies who wish to obtain and capture Aerial photos and videos of said property for purposes including real est ate listings, agriculture monitoring, insurance property claims, inspections, and monitoring structures (roofs) and for use as a marketing tool for businesses. Being an F AA licensed Private Pilot, and a member of the A MA, I therefore underst and the importance of the dif ferent uses and safety concerns regarding F

AA regulated airsp ace, I would be a good candi date for exemption of Sec 333 while not putting Air Safety in any accelerated risk. The specific UAS I intend to use is the (DJI Inspire 1) whose Operating Manual is Included in my petition.) The DJI Inspire 1 UA V includes GPS navigation and many more safe ty systems outlined in the referenced manual. W hen flying for this commercial purpose I would be flying at a maximum altitude of 400 feet with the majority of flight operating at less than 200 feet. Flight s would be mostly vertical f or the purposes of t ak ing photos / video, decreasing the risk of any interference to other aircraft and persons on the ground or in the area. My general knowledge of the aviation safety systems implemented by the F AA would be used to ensure that safety would not be af

fected by my operations. I would not be flying near disaster areas, sporting events, or high traf fic areas including airport s, and I would p ay attention to all NOT

AMS. I appreciate the F AA ’s consideration of this petition for exemption. **The specific section or sect ions of 14 CFR from which y**  **ou seek an exemption;**  Regulations from which the exemption is requested:

- 14 C.F .R. Part 21 (H)

- 14 C.F .R. 61

- 14 C.F .R. 91.103(b)(2)

- 14 C.F .R. 91.105

- 14 C.F .R. 91.109

- 14 C.F .R. 91.1 19

- 14 C.F .R. 91.121- 14 C. F. R. 91.151

- 14 C.F .R. 91.405

- 14 C.F .R. 91.407

- 14 C.F .R. 91.409

- 14 C.F .R. 91.417

**A brief description of the nature of the exemption I am seeking;**  I am p etitioning for an exemption to provide a commercial service to private land owners and comp anies who wish to obt ain and capture Aerial photos and videos of said property for purposes including real est ate listings, agriculture monitoring, insurance property claims, inspections, and monitoring structures (roofs) and for use as a marketing tool for businesses. I would like to be able to accept p ayment for these services therefore making this a commercial use of a UAS.
**An y**  **additional information, view s, or argument** **s available to support y our**  **request;** I am fully aware of the pre flight safety checks and procedures implicated in the operation manual for the DJI Inspire 1 and intend to implement pre flight safety checks and checklists and utilize the safety technology provided with this unit. I intend to only fly in non populated, residential or rural areas and stay clear of all obstacles, utility lines etc. I intend to be fully aware of my surroundings at all times and to only fly the unmanned aircraf t w ithin a visual line of sight and only in Vi sual Flight Conditions. My F AA Issued Private Pilot License Certificate Number is 3638364 My Membership Number in the Academy of Model Aeronautics is 1092266 for 2016 I underst and the and will comply with all t he health and safety regulations for PIC’s and will be the only operator under this exemption. **Description of UA S and Equivalent Level of Safety**  The primary UAS system that will be used is the **DJI Inspire 1** quadcopter (model T600). The UAS will be safely operated in the NAS by maintaining line of sight visual cont act, flown only during daylight, and less than 400ft abovethe ground. Flight s will be operated at a lateral dist ance of no less than 100

feet from any persons or property not associated with the operation. Additional safety features on the DJI Inspire 1 include return to home functionality when GPS is available and failsafe technology that return the aircraf t to the t akeof

f point if the batteries ru n low

. Additionally , the max flight time for the UAS will be limited to maint ain a reserve of 25% battery power

. At all times, the UAS will be operated in accordance with the safety and operational requirements of the manual (see link below .) The specific ations for the UAS **DJI Inspire 1** are as follows: **Weight:** 2935 g **Diagonal Size:** 438 x 451 x 301 mm **Max As**  **cent S peed:**  5 m/s **Max Descent S peed:**  4 m/s Max S peed: 22 m/s (no wind) The Petitioner has supplied the following additional information on the **DJI In**  **spire 1** UAS: **Inspire 1 Specs** http://www.dji.com/product/inspire

- 1/spec **Inspire 1 Quick Start Guide** http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Sta rt_Guide_v1.4_en.pdf **Inspire 1 User Manual** http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Man ual_v1.4_en.pdf **Inspire 1 Safety**

**Guidelines** http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Safety _G uidelines_en.pdf **Inspire 1 Maintenance Manual** http://do wnload.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Maintena nce_ManualV1.0_en.pdf **UA S Operations**  Preflight would include checking the operation of the UAS to include the battery in both the transmitter and the UAS, the condition of the body of the UAS and its propellers. Updates to the firmware will be done as they become available and maintenance will be performed pursuant to the manufacturers recommendations. Th e area in which the drone will be flown will be checked for power lines, antennas, and other obstructions. The weather conditions will be monitored throughout the flight. W ind conditions will be reviewed and the UAS will only be flown in daylight. As the pilot, Brian would ensure that he is safe to operate the drone as though he were flying in the aircraf t himself.Lost Link Event s. Finally, the F AA tweaked it s st andard grant language regarding lost link event s. The FAA ’s previous requirement st ated “[i]f the UAS loses communications or loses its GPS signal, the UA must return to a pre - dete rmined location within the private or controlled
- access proper- ty .” The requirement in the most recent terms st ates that if the pilot loses command or control link, the UAS “must follow a pre
- determined route to either reest ablish link or immediately reco ver or land.” **UA S Operating Parameters**  The petitioner st ates that all flight s will be operated within visual line of sight (VLOS) of pilot, in daytime VFR flight conditions and all operations will be conducted with the assistance of a second spotter/observer . T he UAS flight s will be limited to a maximum altitude of 400 feet AGL. Altitude is accurately measured by GPS. The petitioner further st ates that an operator will ensure that only consenting production personnel will be allowed within 100 feet of the UA operation, and UAS will be kept at least 100’ from any inhabited structure. Generally the petitioner ’s UAS will be operated in rural or suburban areas that will permit significantly larger safety zones. Flight S tandards District Of fices (FSDOs) will b e notified as required prior to operations to describe intended coordination for proposed operation(s). Petitioner will obtain an Air Tr affic Organization (“A TO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting any operations unde r this grant of exemption. In fulfilling its requirement s under the COA, Petitioner will be required to request a NOT AM not more than 72 hours in advance, but not less than 48 hours prior to the operation. Petitioner ’ s UAS will remain clear and yield the right of way to all manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, p arasailing activities, and gliders / hang gliders). Petitioner will not cond uct UAS operations within 5 nautical miles of the geographic center of a non
- towered airport unless a letter of agreement with that airport’ s management is obtained and the operation is conducted in accordance with a Notice to Airmen (“NOT AM”). **Safet y**  **an d Benefit** **s of the UA S**  The petitioner will be using the UAS in a variety of applications that generally require expensive full
- size manned aircraft to complete. Small, light, unmanned aerial vehicles of fer a myriad of benefit s over the use of full
- sized man ned aircraf t for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few . Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no p assengers or crew creates a much greater margin of safety for the pilot s andcrew . By granting Petitioner ’s requested exemptions, the F AA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge bas e for such operations. Petitioner is committed to promoting the UAS research ef forts of policymakers including the F AA, NASA, DOD and DARP A by sharing dat a from its commercial UAS operations and serving as a resource for future UAS research operations. Thu s, the F

AA has good cause to grant this Petition. **If y ou want to exercise the privileges of y**  **our exemption out side the United**  **Sta tes, y**  **ou must st ate the reason.**  I have no intention on using this exemption outside the United S tates
**Conclusion** For the foregoing reasons, the exemptions requested herein should be granted and Petitioner should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the F AA. Thank y ou for your consideration. Sincerely, Brian Gaudet Owner/Pilot St rategic Designs 39 T if fany Cir

. Millbury, MA

01527 bgflyer@icloud.com 508
- 754
- 5664