Taylor D. Hyde 44177 Highway 91 Taylor, Nebraska 68879 1(308)-942-3140 Hyde_ 203020@hotmail.com Date: 11/24/2015

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

Petition ofTaylor D. Hyde for Exemption Pursuant to Section 333 ofthe FAA Reform Act 

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Pursuant to Section 333 ofthe FAAModernization and Reform Act of2012 (the Reform Act) and 14 C.P.R. Part 11 Taylor D. Hyde, operator ofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography and videography, News gathering, Aerial Surveying, training, hereby applies for an exemptionfrom the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations
are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.1

As described more fully below, the requested exemption would permitthe operation ofsmall, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, ifgranted, would allow Taylor D. Hyde to conduct commercial operations ofsmall unmanned aircraft systems ("UAS") meeting or exceeding all ofthe operational and safety requirements Congress has set forth in Section 333. Page 2. Taylor D. Hyde asks that ifany part ofthis request is deemed not in compliance, that part be removed and process the remaining ofthis request as applicable. Taylor D. Hyde plans to exploit the capabilities ofUnmanned Aerial Systems to offer a multitude ofservices, including:

- Aerial surveying

- EventPhotographyNideography

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- News Gathering Statutory Authority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization ofsafe civil UAS operations in the NAS. Section 333(a) states that the FAA "shall determine ifcertain unmanned aircraft

# ---· systems may operate safely in the national airspace system before completion ofthe (comprehensive) plan andrulemaking required by section 332(b)(l) ofthis Act orthe guidance required by section 334 ofthis Act." In Section 332(b)(1), Congress made it clearthat Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitioner meets all requirements to permitFAA approval ofcommercial UAS operations.

The Petitioner Requests ReliefFromthe Following: Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121Page 3 14 C.F.R. 91.15l(a) 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)

Unmanned Aircraft System sUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety.

I ampetitioning for exemptionto enable Taylor D. Hyde to operate the DJI Inspire 1, DJI S900, DJI Phantom 2, DJI Phantom 3, 3DRSolo equipped with a three-axis camera gimbal and using a High-Defcamera. This sUAS has the failsafe function ofthe autopilot system which means when the communication betweenthe Main Controller and the transmitter is disconnected, the outputs ofall command sticks from controller will go to the centerposition. Ifthe GPS signal is good enough, the system will automatically trigger Returnto Home and will land safely.

Aircraft Gross weights are less than 164 oz. with battery and the 3 Axis Camera Gimbal and Camera

A Pre-flight inspection will be performedbythe PIC in accordance withthe factory instruction manual. An added step will be the inspection ofthepropellers. A propeller will be replaced ifit has any nicks and cracks with a manufacturers authorized propeller.The sUAS will be maintained inaccordance with the manufacturers instructionmanual and only manufacturer's authorized replacement parts will be used.

FCC Information This transmitters used for controlling the sUAS complies with part 15 ofthe FCC rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. The radio transmitters used for controlling the sUAS is wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitters in the 2.400GHz to 2.4835GHz frequency range. Antenna SeparationDistance When operating ourtransmitters, the PIC will maintain a separation distance ofat least 5 embetweenhis body (excluding fingers, hands, wrists, ankles and feet) and the antennato meetRF exposure safety requirements as determined by FCC regulations.

Pilot in Command and Observer Qualifications and Duties The PIC will maintain at least a Sport Pilot Certificate and a current Class III medical certificate
or drivers license, plus at least 1hours flying time and 3 takeoffs and landings within the previous 90 days in the type ofUAS utilized in operations. The PIC will have atleast 20 hours total time and at least 10 hours flying Radio Controlled Model Aircraft ofwhich will be 5 hours flying sUAS's. Training will be conducted at a local Controlled Access flying field. Taylor D. Hyde has the ability to safely train new sUAS Pilots. The PIC instructor will be at all times be able assume control ofthe sUAS.

The PIC is responsible for the safe and efficient operation ofthe aircraft. Specific duties include all preflight preparation, in flight operation, postflight requirements, all procedures including but not limited to: Safe in flight operations Risk Mitigation to Persons and property Airfield Suitability

The Observer musthave the visual acuity to observe the sUA V and be able to communicate clearly with the PIC. The Observers duties are; warning the PIC ofany impending obstacles inthe flight path ofthe sUAS. warning the PIC ofany deviations in the planned flight pathofthe sUAS. warning the PIC should any unauthorized personnel appear inthe area ofthe planned flight. The Observer will have the authority to order the PIC to terminate the flight should he feel the flight cannotbe conducted safely.General Operating Standards
Taylor D. Hyde will only operate its sUAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from hazzard areas. Such operations will insure that the sUAS will "notcreate a hazard to users ofthe national airspace system orthe public."

• Before an operation ofa sUA V within 5NM ofan airport with a control tower, the control tower will be called to gain permission to operate the sUAS. The PIC will give the position, altitude and the times the sUAS will be operated. The sUAS will not be operated at an altitude of
over400 feet AGL. Weatherminimums will be 3 miles visibility and a 1000 foot ceiling.

Before an operation ofa sUAS within 5NM ofa non-tower controlled, airport operators will be notified and the PIC will give the right ofway to avoid flying inthe proximity offull-scale aircraft. Atno time will the sUAS be operated within the final approach course and the takeoff
course ofany runway. The sUAS will notbe operated at an altitude ofover 400 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.

• Maximum flight time for each operational flight will be 30 minutes.

• Flights will be terminated at 25% battery powerreserve should that occurpriortothe 30 minute limit.

• The sUA V will beprogrammed so that it will be operated at an altitude ofno more than400 feetAGL.

• Minimum crew for each operation will consist ofthe sUAS Pilot, and Visual Observer.

• The sUA V operatedby the petitionerweighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbals).

• The sUA V will operate at speeds ofno more than 40 knots, canhover, and can simultaneously
move vertically and horizontally.

• Giventhe small size ofthe sUAV and the restricted sterile environment withinwhich they will operate, our sUA V operations adhere to the Reform Act's safetyrequirements.

The UAS, powered bybatteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people onboard and will thereby reduce currentrisk levels andthereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time ofonly 20 minutes, this is offers little orno riskto national security.Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics oflarge, complex properties with several buildings and large trees. The applicants in the pasthave chartered 2-seat full-sized helicopters for this purpose, which has provenmore costly than many potential clients have been able to afford. The benefits ofreduced cost andimproved quality ofpresentation from the UAwill be valuable to and benefit manybuyers and sellers ofreal property as well as mitigating risk by not carrying personnel for flight operations.
(a)No flight will be made with a Gross weight exceeding 55 pounds; 

### (b) All operations mustoccurinFAAallowed Class ofairspace atno more than 400 ft AGL, at
an airspeed ofno more than 40 knots and no further than Visual line ofsightfrom the PIC;
(c) All operations mustutilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation;
(d) All requiredpermits will be obtained from state and local government priorto operation;



### EXEMPTIONREQUESTSAND EQUIVALENTLEVEL OF SAFETY Taylor D. Hyde requests anexemptionfrom the following regulations as well as any additional regulations that maytechnically apply to the operation ofthe sUAs System:



### 14 CFRPart21, Airworthiness Certificates Thispart establishes the procedures for the issuance ofan airworthiness certificate. Whilethe FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificatebe issued for the DJI Inspire, DJI S900, DJIPhantom 2, DJI Phantom 3, 3DR Solo undereither or bothofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a)

### Research anddevelopment. Testing new aircraft design concepts, new aircraftequipment,
newaircraft installations, new aircraft operating techniques, ornewuses for aircraft. (b)

### Showingcompliance with regulations. Conducting flight tests and other operations to showcompliance with the airworthiness regulations including flights to showcompliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function andreliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customercrewtraining, we would expectthat anexperimental certificate would permit our commercial purpose as well. The aircraft will not carry persons orproperty,

# will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructedprimarily ofcarbon fiber and plastic, we propose that the UAwill be atleast as safe, ifnot safer, than a conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFRPart 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined inthe previous paragraph.

14 CFR45.23 Display ofmarks; general and 45.29 Size ofmarks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance in whichthe word "EXPERIMENTAL" can be placed, and may nothave a registration number assigned to itby the FAA. We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" intheplacard
on the top ofthe aircraft, as shown above, where the PIC (Pilot InControl), VO (Visual Observer) and others in the vicinity ofthe aircraft while it is preparing for launch will be able to
see the designation. Additionally, we feel thatthe permanentplacard discussed inthe previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag, sign orbannerthat contains the words "UnmannedAircraft in Use" in letters 

### 3 inches high orgreater. Since the aircraft will operate within Line ofSight ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point oforigin.

14 CFR61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private Pilotcertificate may act as pilot in Command ofan aircraft for compensation orhire. Subparagraph (b) allows a private pilotto act
as pilot in command ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to that business oremployment; and (2) The aircraft does not carry passengers orproperty for compensation orhire. Ourproposed operations require thatthe PIC musthold at least a Sport Pilot Certificate with a Drivers License and since the aircraft cannot carry passengers orproperty, we feel we meetthe intent of61.113 Subparagraph (b) eventhough the intent ofthis application is to conduct a business.

14 CFR91.7 Prohibits the Operation ofan aircraftwithout an airworthiness certificate. As
no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure that flightmanual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would notbe available to the crew during flight operations. To obtain an equivalent level ofsafety and meetthe intent of91.9, we propose that a current, approved sUAS Flight Manual mustbe available to the crew atthe ground station anytime the aircraft is in, or preparing for, flight.



### 14 CFR91.109 FlightInstruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." Training will be conducted at
a local Limited Access flying field. Taylor D. Hyde 

### has the ability to provide " Safe Dual Training". The PIC instructor will be atall times be able assume control ofthe sUAV.



### 91.119 Minimum safe altitudes: General. The regulation states that over sparselypopulated areas the aircraft cannotbe operated closerthan 500 feet to any person, vessel, vehicle, or structure. Since the typical mission ofthe sUAS would be photography or survey ofpersons, vessels, vehicles or structures itwould be necessary to operate closerthan 500 feet to the items listed. Operations will onlybe flown over property orpersons where permissionhas been obtained and careful pre-planned flight pathhas been performed. The aircraft will be operated at a lowaltitude allowing, ifa power unit fails, an emergency landing without undue hazard to persons orproperty onthe surface. Therefore we maintain that due to the small size oftheUAS, the hazard to persons, vehicles and structures is minimal comparedto manned aircraft, which shouldbe considered in granting the exemption.



### CFR91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes byreference to an altimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoffpoint is transmitted viaradio from the sUAS on-board computerto the display screen held bythe PIC, providing a constantly updated AGL readout.



### 14 CFR91.151 Fuel requirements for flight in VFRconditions. The regulation provides that no person may begin a flight inan airplane under day-vFR conditions unless there is enough fuel to fly to the first point ofintended landing andto fly after that for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safetybuffer for delays to landing. The sUAS is battery operated and the maximum duration offlight from a single battery charge is 20 minutes with a 25% reserve. Since the aircraft will never fly more than line ofsight from the point ofintended landing, a full battery charge at launch will ensure that we meetthe reserve energyrequirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

### 14 CFR91.203(a) & (b) 

### Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, withthe registration number assigned to the aircraft and a registration certificate mustbe aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew." At a maximum gross weight of6.1 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers orcrew. To obtain an equivalent level ofsafety and meetthe intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be with the crew atthe ground control station and available for inspection upon request. Inorder to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft viaplacard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR45.23.



### 14 CFR91.205(a), (b), 

### (c) Instrument and EquipmentRequirements This regulation provides a minimum set ofinstruments and equipment required for day and night VFRflight. Due to the small size ofthe sUAS itwould be impossible to carry many ofthese instruments. 91.205 (b) 4,5,6,7,8,13,14,16,17 are not applicable as the sUAS has no Reciprocating engines or seats. 91.205 (b) 2,3,9 are provided on the hand held controller. 91.205(b) 1 is not applicable as the maximum available speed ofthe sUAS is less than the maximum required by this exemption and has no effect onperformance. 91.205 (b) 10 is not applicable as the landing gearposition canbe verified visually before landing. 91.205 (b) 15 Due to the size it would be impossible for the sUAS to carry any known ELT. 91.205 (c) Much ofthis equipment is too heavy to be carriedbythe sUAS. We feel that visual contact with the sUAS and indications provided viathe controller that all critical information can be monitored.



### 14 CFRSubpartE (91.401- 91.417)- Maintenance, PreventiveMaintenance, Alterations The regulationprovides that the operatoris primarily responsible for maintaining the aircraft in
an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for returnto service by a person authorized under 43.7" after maintenance and inspection. Itis our intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure thatthe aircraft is in an airworthy conditionpriorto every flight and in addition conduct detailed inspections after every two hours offlight. Maintenance performed bythe PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All othermaintenance will be performed by the manufacturer ortheir designated repair facility. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety. 

### Safety and Benefits ofthe UAS Taylor D. Hyde will be using the UAS in a variety ofapplications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad benefits overthe use offull-sized manned aircraft for electric power line inspection, oiVgas pipeline inspection, advanced agriculture, film and still photography,justto name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAScarrying no passengers orcrew creates a much greater margin ofsafety for the pilots and crew. By granting Taylor D. Hyde'srequested exemptions, the FAA will help drive development ofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations. Taylor Hyde is committedto promoting the UAS research efforts ofpolicymakers including the FAA, NASA, DOD and DARPAby sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition.

Conclusion Aspointed out in this application, all the SUAs which ourcompany would use, under authorization by the US DOT-FAA, are small, light-weight devices operated within the line of sight ofthe Pilot-in-Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or otherlocation with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance.

All our SUAs have proven capability for controlled flight. They are devices offered for general sale onthe market around the world and have oftenbeenused as Model Aircraft in the USA. We are certain thatthe studies conducted until nowbythe FAA, about Section 332, Public Law 112-95, 2014, have already provided you withthe assurances onthe airworthiness ofSUAs such as ours.

Forthe foregoing reasons, the exemptions requested herein should be granted, Taylor D. Hyde should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate bythe FAA. The submission ofthis application and its contents is the best demonstration that indeed it is possibleto pursue the authorization process so that some SUAs may be used for legitimate commercial activities and under reasonably safe conditions. Ifany individual aspect ofthis request for exemptionbe unacceptable we ask that it be struck alone and the remainder ofthe exemptionbe allowed as requested.