John W. Lewis 5960 Siegen Lane Apt 5207 Baton Rouge, La 70809 E

- Mail: johnlewis1@me.com Ph: (225) 910

- 3394

To Whom I t May Concern, This petition is being submitted on my behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, John W. Lewis, a freelance photographer, hereby applies for an exemption from the Federal Aviation Regulations (FARs) lis ted below to allow operation of my Small Unmanned Aerial Vehicle (s UAV) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption would permit John W. Lewis to pursue his commercial interests in providi ng services to clients using a s UAV for taking photographs for Real Estate purposes, w eddings, birthday parties and other social events. John W. Lewis states that all s UAV flights will occur over private or controlled access property and will do so w ith the property owner's consent and knowledge and that only people who have consented or otherwise have agreed to be wi thin the SUAV’s radius during photography applications. John W. Lewis has demonstrated the ability to safely and effectively fly the sUAV DJI Phantom 3 which will be used for all commercial and private purposes. John W. Lewis complies with all local or dinances and laws regarding the operation of the s UAV, and adheres to all w eather and environmental restrictions or limitations in reference to the operations of s UAV’s . John W. Lewis has been in the amateur photography business for nearly 5 years, and has extensive experience safely flying other DJI brand s UAV’s for hobby and recreational purposes. John W. Lewis has logged nearly 2000 hours safely operating s UAV’s, ran ging from many brands, with a specialty in DJI products. All flights will occur in ordinance with any state or local laws regarding privacy. I, John W. Lewis , am seeking the exemption because I am committed to complying with all of the rules, limitatio ns, guidelines , and future legislation set forth by the FAA. I agree to operate the s UAV in the manner that I have described, and for the purposes that I have described. Without the exemptions request granted, I would be unable to safely and effectively run my new business, and it is my intention to comply with the FAA and obtain an exemption of the following regulations. I have included a list of regulations from which I seek exemption, and a complete list of responsibilities that I assume. I have also included information regarding the aircraft, safety and public benefit. **These are the following regulations from which I seek exemption:** 
14 C.F.R. Part 21 14 C.F.R. 91.103(b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.205(b) 14 C.F.R. 91.215 14 C.F.R. 91.401

– 91.417

**1. Petitioners should describe how the proposed UAS operation will be safely conducted to m**  **inimize risk to the NAS or to persons and property on the ground. Specifically, petitioners should**  **describe the design and operational characteristics for the type(s) of UAS they intend to operate, e.g. aircraft**  **perform ance and perform**  **ance limitations, operating procedures, and aircraft loading inform ation in**  **as much detail as possible. a.**  The s UAV will n ever be flown at heights above 400 ft, with the vast majority taking place below 200 ft. My s UAV is equipped w ith GPS and GLONASS dual

- positioning, making it and the operator completely awar e of it’s location at all times, within 0.5

- 1.0 m. There is a gr ound station for take

- off. This will be a recorded take

- off point that the s UAV will automatically return to for safe landing. This feature is especially beneficial in a low

- battery situation. The s UAV is equipped with sensors that make spatial calculat ions in real

- tim e to offer the safest flight possible. The int elligent battery system on the s UAV continuously calculates it’s distance from the take

- off point and the amount of power needed to return to safely land at the take

- off point. The 6

- axis gyroscope and accelerometer relays even the slightest changes in tilt and movement, offering an unprecedented level of control. Internal ESC’s (Electronic Speed Controls) maintain stable, predictable flight speed
**.** The s UAV has a top speed of 35 mph. The w eight of the s UAV is 1216 grams, or roughly 2.7 lbs. The m ax flight time of the s UAV is 23 minutes.
**2. Petitioners should describe any procedures they would implement, such as pre** 
**- flight inspections,**  **maintenance, and rep air, to ensure that the UAS is in a condition for safe flight** 

. **a.** The s UAV shall only be operated on and flown over private property and with the owner’s consent. There will be a thorough pre

- flight inspection conducted on my private property of the take

- off platform and the aircraft. The s UAV will always be flown in a wide open area. There w ill also be a test flight conducted on my property prior to any o perations to ensure proper function and safety of the aircraft , and that all electronic devices are func tioning appropriately

. All necessary maintenance will be carried out in my shop to the standards of the s UAV manufacturer. All pre

- flight inspections and testing will be repeated after any maintenan ce or service to the aircraft, and prior to any commerci al flight operations.
**3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS and**  **associated equipment that is part of the UAS (i.e., sensors, cam eras, etc.), and whether it com**  **plies with Federal Communications Commission (FCC) or other appr**  **opriate governm ent oversight**  **agency requirem ents.**  **a.** The s U AV operates on a RF spectrum of 2.4

- 2.485 Ghz. Th e ground station operates on either a 900mhz or 2.4Ghz RF. The Wi

- Fi video link has an operating frequency of 2.4

- 2.483 Ghz. The s UAV is in complia nce with all current FCC rules and regulations and meets all current FCC requirements.
**4. Petitioners should describe the qualifications required of any PIC(s) who will be directly responsib**  **le for the operation of the UAS.**  **a.** The SUAV PIC will hold at least a Sport, Recreational or Commercial pilot’s license. The PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate . The PIC operating the s UAV will be required to have a minimum of 100 hours of flight experience with the s UAV used for operations. The PIC must also have a minimum of 40 hours total flight time with the airplane that wa s flown to achi eve their license.
**5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible**  **for the operation of the UAS. a.**  The PIC must hold a current FAA airman medical certificate or a valid U.S. driver’s license issued b y a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. **6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how**  **the proposed operation(s) would not adversely affect safety, or how they would provide a level of** **safety at least equivalent to that provided by the rule from which exemption is sought. Petitioners should address any plans to implement clearly defined operational borders and procedures to ensure**  **public safe ty, which includes persons and property both in the air and on the ground.**  **a. The Specifications Of The**  **DJI Phantom 3**  **Demonstrate Its Safe Characteristics.** The s UAV does not create a hazard to users of the NAS or the public, or otherw ise pose a threat to national security considering its size, weight, speed, and operational capability. **b. The DJI Phantom 3**  **Autonomous Flight And Navigation Modes Enable The sUAS To**  **Rem ain Within A Defined**  **Operational Area.** The DJI Phantom 3 ma y be operated in both manual and full y autonomous flight modes. There will be pre

- defined flight zones set that the sUAS will not be able to fly out of. **c. The DJI Phantom**  **3 Is Designed For Autom**  **atic Return To Hom**  **e Point Or Hover In The Ev**  **ent Of Loss Of The Control Link Or Navigation.**  When the Control Link is lost, the DJI Phantom 3 will rem ain stationary, in flight, for 3 seconds or mo r e. If, after 3 seconds, the DJI Phantom 3 do es not reacq uire control link data from the GCS (Ground Control Station) , the sUAS will assume that the Control Link is lost and the sUAS will return to the home position (i.e., failsafe mode) via GPS and GLONASS , and w ill descend to the takeoff position. **d.** The sUAS will always be operated w ithin VLOS of the PIC, never at altitudes higher than 400ft, and never within 25ft of any structure. The sUAS will never be flown within 5 nautical miles of any airport, helipad or other airport facility. The sUAS will be flown according to all rules and regulations set forth by the FAA. **e.** All persons within the pre

- defined flight area will be notified of the operation. **f.** The intended operation of the sUAS will be for Real Estate photography and special events photography and videogr aphy, such as: weddings, birthday parties, social gatherings. **g.** There will be a spotter present during all flights to assist in the detection of other aircraft.
**7. Petitioners should specify the proposed maximum** **operating speed and altitude, and describe mi**  **n im**  **um flight visibility and distance from clouds for their intended operation(s). Petitioners should**  **describe potential hazards and safety m itigations associated with these proposed conditions.**  **a.** Maximum operating speed of the DJI Phantom 3 is 35 mph. Typica l operating speed will be much less, around 15 mph. Altitude of the sUAS will never exceed 400 ft. The sUAS will never be operated in any visibility of less than 15 nautical miles . The sUAS will never be flown at an altitude high enough to be near any c louds. All proposed hazards w ill be mitigated by following the rules and regulations set forth by the FAA in 14 C.F.R, listed in this petition and within the DJI Phantom 3 Operator’s Manual, which is attached. **8. Petitioners should describe the characterist**  **ics of the area of intended operation(s) and the associated potential hazards, in accordance with the statutory m**  **andate under Section 333. a.**  The intended flight operations w ill largely take place over private property, and only with approval from the land owner. If any operations of the sUAS take place in any public area, all personnel within that area will be notified and made aware of safety measures set in place and all pertinent information regarding the operation of the sUAS. All local laws and regulat ions will be followed during public sUAS operations. Any public operation of the sUAS will only be carried out after permission is granted by local authority and all rules and regulations set forth by that lo cal authority will be followed.
**9. Petitioners**  **should describe if they intend to operate in the proximity of any airports, in accordance with the statutory m**  **andate under Section 333 regarding proximity to airports. a.**  No operations of the DJI Phantom 3 or any other sUAS will be carried out w ithin the prox imity of any airport. All operations will be carried out following the regulations set forth by Section 333. **10. The UAS**  **must be operated within visual line**
**- of** 
**- sight (VLOS), in accordance with the statutory**  **mandate under Section 333(b)(1). Petitioners should describe how they intend to comply with his**  **mandate. a.**  The sUAS will always be operated w ithin VLOS of the PIC. This will be accomplished with the assistance of the Spotter that will be present during all sUAS operations. The PIC w ill be held accountable by

the Spotter to alw ays maintain a VLOS with the sUAS. The PIC w ill operate the sUAS according to all FAA Section 333 guidelines pertaining to VLOS.**11. Petitioners should describe any procedures they would implement for conducting a preflight safety**  **risk as sessment to determ**  **ine that the UAS is in a condition for safe flight (14 CFR § 91.7(b)) and that the planned operation can be com**  **pleted safely. a.**  Preflight inspection of aircraft rotors, camera and gimbal assembly will be carried out in my w ork shop prior to all flight operations in accordance with all manufacturer requirements and suggestions. Preflight inspection along with a test flight will be carried out on John W. Lewis’ private property prior to any commercial operation. Prior to any commercial operation, a preflight safety meeting will be conducted with the PIC and Spotter to address any potential safety hazards, obstructions, atmospheric visibility, weather conditions and any other factors involved with the specific task. **12. The FAA intends to require**  **entities who obtain an exemption under this process to also obtain a Certificate of Waiver or Authorization (COA) from** **the FAA Air Traffic Organization prior to conducting operation(s) in the NAS.**  **a.** If an exemption is granted to me through this petition, Jo hn W. Lewis will obtain a COA from the FAA Air Traffic Organization prior to conducting any operations in the NAS. **I have also attached a copy of the DJI Phantom** **3 Safety Guidelines . All rules, regulations and limitations**  **set forth in the included document**  **will be adhered to.** Thank you for your time in reviewing my petition and it is my great hope and desire that you grant me exemption so that I can safely and effectively operate my new business for the good of my customers and the economy.

Sin cerely, John W. Lewis**The PIC will adhere to the following rules and responsibilities:** 1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to am end this exemption. 2. Operations for the purpose of closed

- set motion picture and television filming are permitted with proper permissions from motion

- picture provider. SUAS must be insured or insurance provided by motion

- picture provider prior to any on

- set flights 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use eithe r groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be oper ated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaide d by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airm an medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated w ithin the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC alw ays maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. Thi s exemption and all documents needed to operate the UAS and conduct its operations in accordance w ith the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists betw een the conditions and 4 limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS −80) may be contacted if questions ar ise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional tes t flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

- flight inspection and de term ine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and l ife limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.13. Under this grant of exemption, a PIC must have a minimum of 1 years worth of advancd sUAS flying experience and training using the DJI Inspire 1. PIC must hold a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC and sUAS must be fully insured thro ugh the current sUAS insurer AerialPak, if there should be a change in insurance providers this exemption must be resubmitted. 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and em ergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the U AS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in th e current FAA Airport/Facility Directory (AFD) or for airports not denoted w ith an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UA may not be operated less than 500 feet bel ow or less than 2,000 feet horizontally from a cloud or w hen visibility is less than 3 statute miles from the PIC. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available pow er for the UA to conduct the intended operation and to operate after that for at least five minutes or w ith the reserve power recommended by the manufacturer if greater. 21. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 22. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 23. The UAS must remain clear and give way to all manned aviation operations and activities at all times. 24. The UAS may not be operated by the PIC from any moving device or vehicle. 25. All Flight operations must be conducted at le ast 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAS, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 26. All operations shall be conducted over private or controlled

- access property with permission fr om the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 27. Any incident, accident, or flight operation that transgresses the la teral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS −80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructi ons containedon the NTSB Web site: www.ntsb.gov

.