William C. Crumlic 24 East 125th Street, A p t 3 New York, NY 10035 T : 646-596-6652 bill@crumlicmedia.com

3/ /14/ 2016 U.S. Department of Transportation, Docket O perations Ground Floor, Rm. W12-140 1200 New J ersey A

ve, SE W ashington, DC 20590

**Regarding: F** 

**A A**  **Exemption Rulemaking Section 333 of the F**  **A A**  **Reform Act and Part 1**  **1- 14 C. F**  **.R. § 45.23(b); 14 C.**  **F .R. Part 21; 14 C.**  **F .R. 61.**  **1 13(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109;**  **1 19.121;**  **91.151(a); 91.203(a) & (b) 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a) & (b)**

Dear Sir or Madam:

I, William C. Crumlic , am requesting exemption from the Federal A viation Regulations (“F

ARs”) listed below and pursuant to the F AA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11. in order to commercially operate a small ultra light unmanned aircraft system (“UAS”), specifically the following UAS platforms will be used:

DJI Phantom 3 4K

Attachment 1 lists the technical specifications for each of the previously listed UAS(s).

I have never had an incident acting as either a pilot flying a UAS.

My Small UAS Certificate of Registration number is FA3NW37XFW

I would like to begin business operations as Commercial photography/videography service provider. Specifically, I would like to do the following:

Real Estate Event Site Planner

Specifically, I wish to provide aerial imaging to its customers in need of aerial photography/videography. With the advancement of Internet technology and consumer adoption of shopping for properties online, the demand for high-resolution aerial graphics and video is unprecedented. In addition, I wish to be able toperform video and still photography recordings for commercial clients such as art galleries and exhibitions to include outdoor art installations by UAS. All UAS pertinent safety and risk management measures as specified in the F

AA ’ s Risk Management Handbook shall be complied with.

A grant of the exemption request, by the FAA, would permit operation of ultra lightweight and unmanned UAS to operate in predetermined areas away from the general public, airports, heliports and vehicular traffic, primarily over individual properties/communities for the purpose of recording real-estate listings and visual art installations. (photo/video).

In summary and in accordance with this request of exemption request as authorized and outlined by the FAA under Section 333(c) of the Reform Act specified for use of UAS’ for “Real Estate” purposes, Thomas G. Wilson will adhere to all FAA regulations at all times and shall conduct all flight operations in strict compliance and safety protocols as mandated and required by regulations and best practices. Respectfully, I request the grant of exemption to operate ultra light weight, remote controlled UAS’s for commercial purposes as described in this request and as allowable by law. This grant of exemption will allow me to offer such services to private and governement entities who have little to no experience piloting UAS’s but have a need to get images that are only possible from a UAS in order to compete within an ever demanding technology driven market. William C. Crumlic submits that this application has been prepared by William C. Crumlic and not an attorney using his personal knowledge of existing FARs as well as utilizing excerpts from other similar applications. Consequently, if I have unintentionally omitted any relative FARs, I, humbly request an opportunity to submit to those accidental omissions. The essence of this application is to declare that, William C. Crumlic meets and exceeds the FAA ’ s expected competency for piloting the listed UASs for commercial purposes and that the UAS that we specified earlier meets and exceeds the safety requirements as set forth by the Secretary of Transportation thereby prompting the request for COA under Section 333. 1. **Contact Information:** William C. Crumlic 24 East 125th Street, Apt 3 New York, NY 1 0035 646-596-6652 bill @ crumlicmedia .com 2. **The Specific section(s) of 14 C.F.R. seeking an exemption from are:** 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

3. **The extent and**  **reason of relief:** 

William C. Crumlic , is seeking relief from existing F ARs that currently prohibit the use of UASs from operating commercially for the purpose of aerial photography/videography in accordance with the F AA Modernization and Reform A ct of 2012 112 P .L. 95 § 331-334. The Re form A ct S ubtitle B: U nmanned Aircraft S ystems – (Sec. 332) “Requires t he S ecretary to develop a pl an to accelerate s afely the integration by September 30, 2015, of civil unm anned aircraft s ystems (U ASes, or drones) into the national a irspace s ystem.” T he c ompany humbly requests t hat i t be a llowed to commercially operate the l isted UASs duri ng the t ime pe riod the F AA i s furt her establishing rules a nd regulations gove rning the ope rations of such craft.

The S ecretary of Transportation has be en asked by Congress t o, among other things, consider whethercertain unmanned aircraft systems may operate safely in the national airspace system before completion of the rulemaking 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 National Airspace System or the public or pose a threat to national security in light of the following:

The UAS’s size, weight, speed, and operational capability; Operation of the UAS in close proximity to airports and populated areas; and Operation of the UAS within visual line of sight (VLOS) of the Pilot and VO

Accordingly, all flights will be conducted by a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 “Operational Requirements for UASs” and with the following restrictions: All aircraft will be made with a UA Gross weight of less than 55 pounds All flights will occur only during daylight hours. All flights will occur at or below 400 feet AGL 5 nautical miles from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operation tower; or 2 NM from a heliport with a published instrument flight procedure. For safety, no flight with winds over 10 mph. Flight only in GPS mode that allows UAS to hover in place when radio controls are released. All operations to be conducted in GPS mode only.

4. **How the request will benefit the public as a whole:** Aerial photography is becoming a critical component of the way a company does business. Aerial photography and videography via UAS allows people to get a vantage point that never used to be possible or economically feasible. It is much too dangerous and expensive to hire a manned aircraft to take many aerial images thereby making the UAS option more cost effective and safer. There simply is not enough UAS Pilots to cover the demand for these images, which is leading to unlicensed UAS operators which ultimately results in untrained and unqualified operators.

5. **Reasons why the**  **exemption would not adversely affect safety; or**  **how the**  **exemption would**  **provide a level for**  **safety at least equal to the**  **existing rule:**

An exemption would not adversely affect safety because this application applies only to aircraft characteristics and applications within FAA specified limitations. These limitations provide for at least an equivalent safety standard. However, the experience of a certificated rated pilot allows him/her to utilize his/her experience in UAS operations thereby exceeding safety and improving airspace operations by allowing aerial imaging clients to choose an pilot that knows how to pilot an aircraft safely and within regulated limits. In addition, by providing unmanned services to the market place, there will be less of a demand for manned operations, which will provide for safer and quieter residential aerial photography.

As previously stated, all flights will be conducted by a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 “Operational Requirements for UASs” and with the following restrictions:

All aircraft will be made with a UA Gross weight of less than 55 pounds All flights will occur only during daylight hours. All flights will occur at or below 400 feet AGL5 nautical miles from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operation tower; or 2 NM from a heliport with a published instrument flight procedure. Extensive, pre-flight briefings are required between the PIC and the VO. A flight plan is required prior to each flight. All aircraft operations must be conducted within manufacturer recommended specifications. All site permissions must be obtained prior to flight.

6. **A summary the FAA may publish in the Federal Register:** 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of the listed UASs permit exemption from Part 21 because the listed UASs meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. The current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such manuals on location with the Pilot. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as all UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations with the Pilot.

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. The listed UASs are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. The PIC can achieve an equivalent level of safety as achieved by current Regulations because the listed UASs do not carry any pilots or passengers. Further, the PIC possess an FAA pilot certificate, whichhelps his remote control piloting skills and factors in his experience in assessing any flight risks. The risks attended to the operation of the listed UASs are far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing the PIC to operate the listed UASs and meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. The listed UASs will never operate at an altitude greater than 400 ft AGL. The PIC will also operate the listed UASs in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of the listed UASs, an equivalent or higher level of safety will be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 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. . . ”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to the listed UASs. However, as a safety precaution the UAS which will be used will be inspected before and after each flight.

**In Summary:**

William C. Crumlic , respectfully request that the FAA grant the exemption request and further volunteer
any information gathered during flights in the event the FAA is interested in live field data. William C. Crumlic

, agrees and attests to adhere to any further limitations the FAA imposes, now or in the future. Satisfaction of the current criteria provided in Section 333 of the Reform Act of 2012 – size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security – provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of the listed UASs for commercial purposes. William C. Crumlic looks forward to support the FAA and UAS community in its quest to establish proper regulations and protocols for the safe introduction of unmanned aircraft into the national airspace.

Sincerely,

William C. Crumlic 24 East 125th Street, Apt 3 New York, NY 10035 646-596-6652 bill@crumlicmedia.comAttachment 1

**DJI Phantom III Pro** (http://www.dji.com/product/phantom-3/spec)

Weight (Including Battery And Propellers): 1280 g Diagonal Size (Including Propellers): 590 mm Max Ascent Speed: 5 m/s Max Descent Speed: 3 m/s Hover Accuracy

Vertical: +/- 0.1 m (when Vision Positioning is ac- tive) or +/- 0.5 m Horizontal: +/- 1.5 m Max Speed: 16 m/s (ATTI mode, no wind) Max Altitude Above Sea Level: 6000 m Operating Temperature: 0(C) to 40(C) GPS Mode: GPS/GLONASS