## Carrie A. Rickey 629 W. Knoll Crest Drive Peoria, IL 61614 Phone: 309-323-4409 Email: carrierickey@gmail.com June 30th, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE Washington, DC 20590 RE: Petition of Carrie A. Rickey (“Petitioner”) for an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, I, Carrie A. Rickey (“Petitioner”), herby applies for an exemption from the Federal Aviation Regulations (“FARs”) identified below, to allow commercial operations of small unmanned aircraft and associated elements (“sUAS”), so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. An exemption is being requested because (1) existing regulations will burden the Petitioner, (2) Petitioner can provide a level of safety that is equal (or greater than in many cases) to those provided by existing rules and (3) the request is in the public interest. The FAA ʼ s authority to issue exemptions from operating rules, and the Secretary ʼ s authority granted by Section of P.L.112-95, Special Rules for Certain Unmanned Aircraft Systems provide an opportunity to authorize certain sUAS operations in the National Airspace System (“NAS”) prior to implementation of the sUAS rule. This incremental step will allow the Petitioner ʼ s sUASs to safely and legally enter into the NAS. As described more fully below, the requested exemption would permit the Petitioner to operate small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined, and 3) controlled and would 4) provide safety enhancements to the already safe operations of those aircrafts of similar size, weight, speed and operating capability that have been granted entry into the NAS via the rules in the Academy of Model Aeronautics (AMA) National Aircraft Safety Code. 1

1 See the attached “AMASafteyCode.pdf” document.The proposed exemption, if granted, would allow the Petitioner to conduct commercial operations of small unmanned aircraft systems (“sUAS”) meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333 of the Reform Act.
Petitioner is requesting exemption from the following regulations: 14 CFR Part 21, Subpart H 14 CFR 61.23 (a) 14 CFR 61.113(a) and (b) 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.405(a) 14 CFR 91.407(a) (1) 14 CFR 91.409(a) (2) 14 CFR 91.417(a) and (b) This exemption application is expressly submitted to fulfill Congress ʼ goal in passing Section 333 (a) through (C) of the Reform Act. This law directs the Secretary to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS, to the public, or pose a threat to national security. Section 333 of the reform Act grants the Secretary authority to determine (1) if an unmanned aircraft system, as result of its size weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight (VLOS) does not create a hazard to users of the NAS or the public or pose a threat to national security, and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 49 USC 44704 is required for the operation of civil (non-governmental) UASs. Therefore, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system. 2 Carrie A. Rickey 2# # # # # # # # Section 333 Exemption Petition

2 The Petitioner interprets this provision to place the duty on the Secretary to not only process applications for exemptions under section 333 of the Reform Act, but for the Secretary to craft conditions for safe operations of sUAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.Operational Overview Currently, unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe legally operate similar lightweight, remote controlled sUASs. The Petitioner has personally instilled safety protocols and controls to further avoid and prevent public hazard, as well as manned aircraft hazards and catastrophe.
The Petitioner ʼ s current and anticipated sUASs are quad copters, weighing 5 or fewer pounds (including payload). The sUASs have the capability to hover and move in the vertical and horizontal planes simultaneously. They will operate only in visual line of sight (VLOS) and will operate only in tightly controlled and limited airspace. They are capable of operating at speeds of up to 33mph, but will be routinely operated at much lower speeds. They will be operated below 400 feet above ground level (AGL), and never above 400 feet AGL.
The Petitioner ʼ s exemption request would permit commercial operation of the Petitioner ʼ s sUAS for commercial aerial photography and videography in tightly controlled and limited airspace. Aerial photography and videography services will be offered to individuals, business owners, homeowners, realtors, home builders, contractors and/or home inspectors for use in, promotional aerial photography and videography, educational materials and resources, real estate marketing and safer inspections of home exteriors. All operations will be conducted on private and/or controlled access property and with the written and/or oral permission of the property owner(s)/operator(s). Operation will always be conducted in areas that are clear of all people, except the pilot in command (PIC), the PIC ʼ s helper(s) and individuals that are directly involved in the photography/videography production. Such operation will ensure that the sUAS will “not create a hazard to users of the national airspace system or the public”. 3 Granting the Petitioner ʼ s request comports with the Secretary of Transportation ʼ s (FAA Administrator ʼ s) responsibilities and authority to not only integrate sUAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [sUAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of sUAS's for Cinematography/Photo purposes. Further, the Petitioner will conduct operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below the Petitioner respectfully requests the grant of an exemption allowing the Petitioner to operate ultra lightweight, remote controlled sUASs for community awareness to benefit/stimulate attraction to the Central Illinois area and to enhance real estate listing videos for homeowners who cannot afford expensive manned aircraft for the same purpose. Both of which will promote local economic Carrie A. Rickey 3# # # # # # # # Section 333 Exemption Petition

3 Reform Act Section 333 (b)growth through increased employment and increased tax base along with keeping public safety in mind by eliminating heavier manned aircraft containing combustible fuel that poses potential public hazard. Aircraft The Petitioner operates the Solo sUAS manufactured by 3DRobotics, 4 North America ʼ s largest consumer and commercial drone manufacturer. Solo is considered to be the first “Smart Drone”. Solo is a small unmanned aerial vehicle powered by four motors and four propellers. Solo ʼ s onboard computers control navigation, attitude, and communications in flight while sending real-time telemetry and video output and receiving control inputs over the 3DR Link secure Wi-Fi network. It ʼ s motor-to-motor dimension is 18”, it stands 10” high and weighs only 3.3lbs. Solo is powered by the 3DR Pixhawk 2 autopilot system and APM:Copter flight control software. Solo communicates with the controller and Solo app over the 3DR Link secure Wi-Fi connection. 5 Solo ʼ s handheld controller provides control mechanisms and displays in-flight data on a full-color screen. Using twin long range antennas, the controller acts as the central hub for all communication on the 3DR Link network, receiving all communications from Solo and the app, forwarding telemetry outputs to the app, and managing the transmission of all control inputs to Solo. The controller also doubles as Solo ʼ s “black box”: Its 1 GHz computer automatically saves valuable flight data along 500 parameters directly to its internal memory, 20 times a second. Solo uses the controller ʼ s main data display to monitor Solo ʼ s status in flight. Such systems include, battery percentage, GPS signal strength, active mode, Wi-Fi signal strength, horizontal distance from launch point, and current altitude. Solo also has LED flight indicators beneath each of its four rotor arms for ground-to-air directional awareness. The newest features in drone flying include Haptic Feedback, User-Definable A/B buttons, Auto Takeoff and Auto Land buttons, Pause (ebrake) and a Return and Land at Home button. All available with Solo. The Return Home function will automatically land at the home position. This feature can be activated at any time with the push of a button. When activated, the Solo will automatically fly itself back to the place its motors were first started and land without any help from the pilot. Carrie A. Rickey 4# # # # # # # # Section 333 Exemption Petition

4 See attached 3DRSoloManual.pdf

5 http://3drobotics.com/solo-drone/As an added safety feature, the Solo has a dedicated Pause button to immediately bring Solo to a midair halt-and-hover so you can regain your bearings. Such highly advanced capabilities will ensure that the sUASs can be safely operated and “not create a hazard to users of the national airspace system or the public.” 6 Equivalent Level of Safety In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in the world and to minimize the risk to the NAS or to persons and property on the ground, the Petitioner agrees to be bound by the following limitations and conditions when conducting commercial operations under an FAA issued exemption:
1. For the purposes of ensuring sUASs will be operated within the standards that the FAA has allowed in the AMA National Model Aircraft Safety Code: a. sUASs will not be flown:

- In a careless or reckless manner.

- At a location where sUAS activities are prohibited.
2. sUAS pilots will: a. Yield the right of way to all human-carrying aircraft.
b. See and avoid all aircraft and a spotter must be used when appropriate. 7

c. Not fly higher than 400 feet above ground level or within five (5) miles of an airport without notifying the airport operator.
d. Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed-use agreement.

e. Not exceed a takeoff weight of 55 pounds (including payload).
f. Ensure the aircraft is identifiable by affixing the owner ʼ s contact information to

the outside of the sUAS.
g. Not operate sUASs while under the influence of alcohol or while using any drug that could adversely affect the PIC ʼ s ability to safely control the model.
h. Not operate sUASs carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a hazard to persons or property. Carrie A. Rickey 5# # # # # # # # Section 333 Exemption Petition

6 Reform Act Section 333(b)

7 AMA Document #540-D3. sUASs will not be flown unless: a. The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event.
b. An inexperienced pilot is assisted by an experienced pilot.
4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.
5. A successful radio equipment ground-range check in accordance with manufacturer ʼ s recommendations will be completed before the first flight of a new or repaired model aircraft.
6. sUASs must use the radio-control frequencies currently allowed by the Federal Communications Commission (FCC).
7. sUASs will not knowingly operate within three (3) miles of any pre-existing flying site without a frequency-management agreement. 8
8. Excluding takeoff and landing, no sUASs may be flown outdoors closer than 25 feet to any individual, except for the PIC and the PIC's helper(s) located at the takeoff site.
9. Under no circumstances may a pilot or other person touch a sUAS in flight while it is still under power, except to divert it from striking an individual.
10. The PIC of the sUAS shall: a. Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot.
b. Fly using the assistance of a camera or First-Person View (FPV) only in accordance with the procedures outlined in AMA Document #550.

c. Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560.
11. The flying area must be clear of all utility wires or poles and an sUAV will not be flown closer than 50 feet to any above-ground electric utility lines.
12. The flying area must be clear before the engine is started, except for PIC and the PIC's helper(s). Carrie A. Rickey 6# # # # # # # # Section 333 Exemption Petition

8 AMA Documents #922 and #923In addition to the above rules outlined by the AMA National Model Aircraft Safety Code and in an effort to enhance the safety offered by the already safe operations mentioned above, the Petitioner also agrees to be bound by the following limitations and conditions:
1. Flights will be operated with VLOS of the PIC.
2. Maximum total flight time for each operational flight will be 25 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 25 minute limit.
3. The sUAS will only operate in tightly controlled and limited airspace.
4. A briefing will be conducted in regard to the planned sUAS operations prior to each flight. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing.
5. The PIC and the PIC ʼ s helper(s) will have been trained in operation of sUAS and received up-to-date information on the particular sUAS to be operated.
6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice.
7. If the sUAS loses communications or loses its GPS signal, the sUAS will have capability to return to a pre-determined location within the security perimeter and safely land.
8. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.
9. All flights will be conducted on private property and with the written and/or oral permission of the property owner(s).
10. Flights will always be conducted in areas that are clear of all people, except for the PIC and the PIC's helper(s).
11. All flights will be conducted outdoors in visual meteorological conditions (VMC) and never during severe weather conditions.
12. Flights will not occur in weather conditions that prevent the PIC from operating within visual line-of-sight (VLOS) at all times or in weather conditions that dramatically affect the sUAS ʼ s flight (e.g. high winds).
13. If an operation occurs in an area where people could inadvertently enter the area, an operational border will be established with traffic cones. If it ʼ s not feasible to use traffic cones due to interference with the photography/ videography, the PIC's helper(s) will be responsible for keeping a safe perimeter Carrie A. Rickey 7# # # # # # # # Section 333 Exemption Petitionaround the operation. The operation will cease immediately and be rescheduled if it ʼ s impossible to establish a safe perimeter around the operation.
14. The PIC will be responsible for logging all flights to ensure the comprehensive preventative maintenance plan can be followed, as described in the “Preventative Maintenance” section below.
15. The sUAS will not be routinely operated in the proximity of any airports. In any cases where the sUAS must be operated within five (5) miles of an airport, the airport operator will be notified before the operation commences. The operation of sUASs, weighing less than 3 lbs., conducted in the strict conditions as outlined above, will provide an equivalent level of safety supporting the grant of exemptions requested herein, including exempting the Petitioner from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled environment. As a result, they offer a much safer way to capture aerial photography and videography. Furthermore, the proposed operations represent a safety enhancement to the already safe operations that have been granted by the FAA for the establishment of the AMA National Model Aircraft Safety Code. Preflight Plan The PIC will follow a comprehensive pre-flight checklist to ensure that the sUAS is in a condition for safe flight. This plan will be improved as needed in order to ensure all known safety precautions and/or safety precautions suggested by the manufacturer are being accounted for.
A. Pre-flight Inspection
1. Check that the transmitter, sUAS and camera batteries are all fully charged.
2. Verify that the sUAS battery is not swollen or damaged in any way.
3. Turn the motor shafts with your fingers and verify that are smooth without excessive play or binding.
4. Verify that the propellers are mounted correctly and free from signs of damage.
5. Run finger along the edge of blade to check for any rough edges.
6. Flex both sides of the propellers ʼ blades to check for hairline cracks where the blades connect in the center of the propeller.
7. Verify that the landing gear is secure and free from damage, broken or loose. Carrie A. Rickey 8# # # # # # # # Section 333 Exemption Petition8. Verify that the camera is secure and clean. Inspect the camera connections and gimbal for tears and/or signs of wear.
9. Verify that the damping absorbers are not broken and/or worn.
10. Verify that the Micro-SD card has been inserted and formatted.
11. Verify that the smartphone ʼ s Wi-Fi is enabled.
12. Set the smartphone to do-not-disturb mode to prevent distractions while flying.
13. Set the smartphone to forget any Wi-Fi networks in range in order to prevent the Wi-Fi connection from changing mid-flight.
B. Power Up
1. Power on the transmitter with the flight mode set to the appropriate setting, the throttle stick down and the throttle trim at neutral.
2. Install a charged battery in the sUAS.
3. Wait for the GPS signal to be acquired, which is indicated by a solid LED. It may take from 30-90 seconds to acquire a GPS signal.
4. Move the aircraft to the desired home location and orient the aircraft pointed away from the pilot.
5. Step back approximately 15 feet (5 meters) from the home location. C. Ready to Fly
1. Power on camera and acquire Wi-Fi signal on smartphone.
2. Once smartphone has acquired Wi-Fi signal start camera app.
3. Verify that the aircraft still has GPS lock.
4. Start the motors.
5. Verify that the motors are functioning normally, are not making any unusual noises, and are all spinning the same speed.
6. Verify that the area is still clear of obstructions, people, power lines, etc. Carrie A. Rickey 9# # # # # # # # Section 333 Exemption Petition7. Take off and hover about 6-8 feet above the takeoff point to verify that the aircraft still has a solid GPS lock. If any abnormalities are noticed (drifting, flying in circles, etc.), land immediately and repeat the “Pre-flight Inspection” and Power Up” sequences. 8. Verify that the aircraft holds a steady position while yawing 360 degrees.
9. Verify that the aircraft responds appropriately to all controls – yaw, pitch, roll and throttle. D. After Flight
1. Turn off the power switch on the aircraft.
2. Turn off the power to your transmitter. 3. Unplug and remove the battery from the aircraft.
Preventative Maintenance A comprehensive preventative maintenance plan will be followed in accordance with the manufacturer ʼ s specifications to ensure the sUAS ʼ s software is up-to-date, the batteries are in good health, and the aircraft itself is always ready for safe flights. 9 Pilot in Command (PIC) Qualifications The PIC does not currently hold an airman certificate or medical certification. Since the sUAS is similar in size, weight, speed, and operating capability as those currently allowed to be flown for hobby/recreation, holding the PIC to those same set of standards will allow for an equivalent level of safety. It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlled pre-approved airspace. Since there are no standards for either private or commercial sUAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operation of the sUAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. The PIC would be required to successfully complete an FAA approved ground training course and be required to do the following prior to the first commercial flight: A. Perform 50 flights or log 20 hours of flight time (the greater of the two) with the sUAS that will be piloted. Carrie A. Rickey 10# # # # # # # # Section 333 Exemption Petition

9 See “Maintenance” on page 39 of the of the attached “3DRSoloManual.pdf”B. View and become familiar with all the videos in the Flight School section of the Solo App. 10 C. Study and be familiar with all sections of the User ʼ s Manual of the SUAS that will be piloted. 11 With that in mind, the Petitioner proposes that its PIC be entitled to apply for, and receive a temporary license certificate, renewable until the FAA creates an “unmanned aircraft certificate with sUAS rating”. Public Interest Granting this exemption would benefit the public as a whole. sUASs offer a strong equivalent level of safety, a reduction in environmental impacts, and are free from the harmful emission associated with the manned aircraft that are currently used for aerial photography and videography. Due to the size of the sUAS and the tightly controlled and limited airspace in which the sUAS will operate, approval of this application presents no risk to the public. Furthermore, the public will be able to legally acquire aerial photography and videography to help in, but not limited to, advertising homes for sale, advertising uninhabited homes, lots, use of photos and video as an aid when researching homes for sale on the market, or safely accessing high and/or awkward areas of home exterior to assess damage that needs to be repaired. Privacy Since the areas being photographed or filmed will be on private property, accessed only after given written and/or oral consent by the property owner(s), and clear of all people, except for the PIC and the PIC ʼ s helper(s), approval of this application presents no risk to the public ʼ s privacy. National Security Due to the size of the sUAS and the tightly controlled and limited airspace in which the sUAS will operate, approval of this application presents no risk to national security. Carrie A. Rickey 11# # # # # # # # Section 333 Exemption Petition

10 See “Flight School” on page 15 of the the attached “3DRSoloManual.pdf”

11 See the attached “3DRSoloManual.pdf”Requested Exemptions Petitioner requests exemption from the following regulations since it ʼ s not possible to fully comply with them, and since attempting to follow them for the purposes of operating a sUAS would be a burden: Airworthiness Certificates - 14 CFR Part 21, Subpart H Subpart H establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Petitioner, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC 44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without the restrictions and conditions proposed. Medical certificates - 14 CFR 61.23 (a) This regulation requires pilots of manned aircraft to hold a medical certificate. Since risks associated with the operation of the proposed sUAS are so diminished from the level of risk associated with any manned aircraft; the sUAS is of a size, weight, speed, and operational capabilities which makes it much safer than any manned aircraft; since operations will occur in tightly controlled and limited airspace; and considering that all operations will be on private/controlled access property that is clear of all people, obtaining and maintaining a medical certificate would not improve the safety of the operation. In the very rare case of a mishap, the sUAS being flown will pose significantly less of a threat than manned helicopters and fixed wing aircraft because the sUASs are a fraction of the size, a fraction of the weight, will be flown at a fraction of the speed, carry no flammable fuel, and carry no crew or passengers. Private pilot privileges and limitations: Pilot in command - 14 CFR 61.113 (a) and (b) These regulations limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers; due to the sUAS ʼ s size, weight, speed, and operational capabilities; and since operations will occur in tightly controlled and limited airspace, the proposed operations can achieve the equivalent level of safety of current operations that currently require a commercial pilot ʼ s license. Carrie A. Rickey 12# # # # # # # # Section 333 Exemption PetitionThe FAA has determined that the airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for the petitioner ʼ s specific proposed operations of a sUAS. Although the FAA does not possess the authority to exempt the Petitioner from the statutory requirement to hold an airman certificate, as prescribed in 49 USC Section 44711, it does possess the authority under 14 CFSR 61.17 (a) to grant a temporary pilot certificate or rating, and in accordance with 14 CFSR 61.13 (4) the Administrator must issue an airman certificate “... to an applicant who satisfactorily accomplishes the training and certification requirements for the certificate, rating, or authorization sought, is entitled to receive that airman certificate, rating, or authorization.” With regard to the Petitioner ʼ s PIC training program, the Petitioner has proposed that prior to the first commercial operation the PIC be required to perform the grater of 50 flights or 20 hours of flight time with the Solo, as well as review all the videos in the Flight School App and study and be familiar with the Solo manual identified in the petition. In its proposed regulations, the FAA states that it will create a new “unmanned aircraft operator certificate with a small UAS rating.” This certificate would be required before a person could legally operate a commercial UAS. To obtain this new certificate, an operator—who would need to be at least 17 years old—would have to pass an aeronautical knowledge test at an FAA approved testing center. The applicant would also have to pass a security screen conducted by the Transportation Security Administration. Given the above, the FAA must determine the appropriate level of pilot certification for the Petitioner ʼ s proposed operation: 1) There are currently no standards for either private or commercial sUAS pilot certificates, 2) the FAA has found that it cannot be assumed that a commercial pilot, approved to operate a manned helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlled pre-approved airspace, 3) to require the Petitioner to obtain a certificate rating equal to what ʼ s required to operate a manned aircraft creates a burden and places undue economic hardship on the Petitioner. Therefore, the Petitioner is hereby seeking the Secretary ʼ s approval to apply for, and receive a temporary license certificate, renewable until the FAA creates an “unmanned aircraft certificate with sUAS rating”. Because a temporary pilot certificate is subject to the same security screening by the Department of Homeland Security that all certified airmen undergo, the proposed operations can achieve the equivalent level of safety of recently approved Section 333 exemptions. Carrie A. Rickey 13# # # # # # # # Section 333 Exemption PetitionFlight instruction - 14 CFR 91.109 This regulation provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. Small UASs and remotely piloted aircraft, by their design, do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Minimum Safe Altitudes – 14 CFR 31.119 (c) This regulation prescribes safe altitudes for the operation of civil aircraft and specifies that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. It allows helicopters to be operated at lower altitudes in certain conditions. The Petitioner ʼ s sUASs will never operate at an altitude greater than 400 feet AGL. Since the typical mission of the Petitioner ʼ s sUASs would be to photograph/video structures it would be necessary to operate closer than 500 feet to the items listed. Flights will only be conducted over property where permission has been obtained and at a distance greater than 30 feet of any consenting individual, and only after careful pre-planning has been performed. Further, the sUAS will operate at a very slow airspeed, and a low mass, and do not need as much space to operate safely, as outlined in 91.119. Given the Petitioner will only operate his sUASs in safe areas away from public and traffic, thereby providing a level of safety at least equivalent to those in relation to minimum safe altitudes, and due to the size, weight, maneuverability and speed of the Petitioner ʼ s sUAS, an equivalent or higher level of safety will be achieved. Altimeter settings - 14 CFR 91.121 This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Fuel Requirements for Flight in VFR Conditions - 14 CFR 91.151 (a) This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed – Carrie A. Rickey 14# # # # # # # # Section 333 Exemption Petition(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the proposed sUAS provides approximately 20 minutes of powered flight with attachments. That would make it impossible to meet the 30 minute reserve requirement. Given the limitations on the sUAS ʼ s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. An equivalent level of safety can be achieved because Solo ʼ s battery has a built in feature that tells Solo to return to its home when the battery reaches a point where it would be unable to return to its flight origination point. This is no less that 25% of the battery ʼ s life. This feature would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.
Maintenance Inspections - 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b) These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply. The operator, pursuant to the manufacturer ʼ s user manual and guide will accomplish maintenance. An equivalent level of safety will be achieved because these small sUASs are very limited in size, will carry a small payload, and operate only in restricted areas for limited periods of time. If mechanical issues arise, the sUAS can land immediately and will be operating from no higher than 400 feet AGL. As outlined in the aforementioned Pre-flight Plan, the operator will ensure that the sUAS is in working order prior to initiating flight and perform maintenance as required. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. In accordance with 14 CFR Part 11, the following summary is provided for publication in the Federal Register: The Petitioner seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b) to commercially operate small unmanned aircraft systems Carrie A. Rickey 15# # # # # # # # Section 333 Exemption Petition(55 lbs. or less) in order to safely and legally capture aerial photography and videography for use by business owners, homeowners, realtors, home builders, home contractors, and/or home inspectors. The operation of sUASs conducted in the strict conditions outlined above, will provide an equivalent and/or greater level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in sterile environments, and as a result, are far safer than existing operations conducted with helicopters operating in close proximity to the ground, people, or other buildings in the vicinity. Given the small size of the sUASs involved, the slow speed at which they must be operated in order to capture photos and videos, and the restricted environment within which they will operate, the Petitioner demonstrates that it can be operated within an equivalent level of safety in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUASs to commence. Also, due to the size of the sUASs and the restricted areas in which the relevant sUASs will operate, approval of this application presents no threat to national security. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, the strong equivalent level of safety surrounding the proposed operations, the significant public benefit – including enhanced safety, reduction in environmental impacts, zero emissions, ability to legally obtain aerial photography and videography services – the grant of the requested exemptions is in the public interest. Accordingly, the Petitioner respectfully requests that the FAA grant the requested exemption. Satisfaction of the criteria provided in Section 333 of the Reform Act – size, weight, speed, operating capability, proximity to airports and populated areas, operation within the visual line of sight, public safety, and national security – provide more than adequate justification to grant the Petitioner the requested exemption, allowing for commercial operations as described herewith.

Respectfully submitted,

Carrie A. Rickey, Petitioner Carrie A. Rickey 16# # # # # # # # Section 333 Exemption Petition