August 31, 2015 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 2012 References: 1. FAA Exemption No. 11138, Regulatory Docket No. FAA

­ 2014

­ 0481 in the matter of the petition of DOUGLAS TRUDEAU 2. FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3. FAA Exemption No. 11080 Regulatory Docket No. FAA

­ 2014

­ 0355 in the matter of the petition of FLYING CAM INC 4. FAA Exemption No. 12626 Regulatory Docket No. FAA

­ 2015

­ 2481 in the matter of the petition of Mr. Matthew Robert Pearce Dear Sir or Madam, In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012 , I John Corona, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§ 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 91.409(a)(2); 91.417(a) & (b) In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial data collection and other flight operations that could 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. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required bySection 333. The conditions identified and proposed by the petitioner are drawn from references 1

­ 3. Name and Address of Petitioner John Corona 11-02 Underwood Place Fair Lawn, New Jersey 07410 e-mail: johncorona@optonline.net
The FARs The petitioner seeks exemption from the above mentioned FARs for the following reasons: 61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who hold a SPORT PILOT (or greater) certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions. 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA 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 responsible operations in areas of subdivisions and neighborhoods if required.
91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION 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 UAbatteries provide 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 daytime 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 (DOUGLAS TRUDEAU), 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 recordkeeping, were sufficient to ensure that safety would not be adversely affected. The UAS Unmanned Aircraft Systems: DJI Phantom 3 UAS Petitioner seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 1,280 grams (2.8 lbs.), while having a diagonal size (including propellers) of 590mm (23.2 inches) and a maximum speed of 16 m/s (35.7 mph) (ATTI mode, no wind). The DJI Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. User manual is available for download at: http://download.dji-innovations.com/downloads/phantom_3/en/ Phantom_3_Advanced_User_Manual_v1.4_en.pdf Risk mitigation The petitioner has 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 risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure

­ prone components.The petitioner request that in a manner similar to reference 3, he be allowed to operate within 5 miles of an airport provided that; “ The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non

­ towered airport as denoted on a current FAA

­ published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request .” Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack of mode C transponder.
Public interest Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, 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 designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis. A visual observer will be utilized. Liability insurance will be obtained commensurate with the granting of this request for exemption. Flight data including UA flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as required. Federal Registry Summary Pursuant to 14 C.F.R. Part 11, John Corona offers the following summary for publication in the Federal Register, should publication be necessary: John Corona seeks exemption from the following sections of Title 14, Code of Federal Regulations §§ 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a) (1); 91.409(a)(2); 91.417(a) & (b)Approval of these exemptions will permit John Corona to provide aerial data collection using unmanned aircraft systems (“UAS”) operations. The exemptions will enhance safety by reducing risk to the general public and property owners from the risk and hazards associated with performing equivalent work through conventional manned aircraft. Conclusion The petitioner is requesting this exemption for the purposes of “aerial data collection”. The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptions. The petitioner's business model is based on the idea of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. Market research shows a demand for these services currently exists. The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance. The petitioner believes the conditions identified and proposed by the petitioner are similar to those drawn from references 1

­ 4, permitting the issuance of a summary grant where the FAA finds that it has already granted a previous exemption similar to the new request submitted by the petitioner for aerial data collection. Respectfully submitted, John Corona