U. S . Department of Transportation Docket Management System

1200 New Jersey Ave., S E Washington , DC 20590

Peter J

. Greer

Miles of Grace L.L.C.

10607 Direct River Drive Coon Rapids, MN 55433 (612)723

- 1031 peter.greer@milesofgrace.net

CURRENT PETITIO N FOR EXEMPTION 333
I, PETER J

. GREER , submit the following:

Summary of request: I am submitting this petition pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, so that I may operate the DJI Inspir e 1 quadcopter unmanned aircraft system (UAS) for the limited purpose of conducting aerial pho tography and videography below 4 00 feet AGL and further than 5 miles from any airport or heliport, in order to safely and legally capture aerial photography and

v ideography

.

In comparison , Exemption No. 11192 (which is essentially identical to my request), an exemption was approved for an individual with a Commercial Pilots license. I currently

hold a n Airline Transport Pilot certificate , as well as a current CFI /MEI. Aerial photography and videography operations for private and/or commercial properties and businesses benefit the public with enhanced perspectives of characteristics, amenities, and benefits a property has that cannot be displayed through ground le vel photography and videography. W hile this is essentially the same request as the one g ranted under Exemption No. 11977 / Regulatory Docket No. FAA

– 2015

– 1478 , my request goes

further

, in that I hold a n ATP

.

Thank you for your time and attention to my req uest.

Yours truly,

Peter J

. GreerSections from which exemptions are sought:

a. FAA Modernization and Reform Act of 2012, PL 112

- 95 FEB. 14, 2012, Section

333

b. 14 CFR Part 21, subpart H

c. 14 CFR Part 61.113(a) and (b)

d. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

Public benefit: Use of sUAS technology to obtain imagery, information and data currently o btained by use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., power line inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging failures d uring stack or bridge inspections).

ii. Reduces the cost of obtaining such information, which benefits consumers and the

economy. iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions

from manned aircraft.

All fl ight operations will comply with the following:

i. The manufacturers' Aircraft Flight Manuals and Operation Guidelines

ii. Conducted in VMC conditions during daylight hours.

iii. PIC and VO will maintain VLOS at all times.

iv

. Pre

- flight inspections (including ground control station ) and a safety risk assessments will be conducted prior to each flight.

v. Flig ht altitudes will remain below 4 00 feet above ground level.

vi. Flight ground speeds will not e xceed 40 knots.

vii. Not intrude into Class B, C or D airspace, or published approach,

SID or STAR, or take place within 5 nautical miles of an airport. viii. Not be made near persons as required in 14 CFR 91.119 and not over persons on the g round without their prior permission.

ix. Each flight will be logged in both the PIC's logbook and the aircraft logbook.x. Not exceed 80% of the battery capacity of the aircraft, or 30 minutes,

which ever occurs first.

xi. Any incidents wil l be reported to NTSB within 24 hours of occurrence.

xii. Miles of Grace L.L.C will maintain liability insurance of at least $1,000,000 issued by a major aviation insurance underwriter.

xiii. Any applicable local FSDO requirements.

xiv. All other applicable regulations concerned with the operation of

aircraft.

THE UNMANNED AIRCRAFT (UA) DJI Inspire 1

• Professional grade

• Under 15 pound s takeoff weight

• 4 motors

• 15 t o 20 minute flight time depending on battery size

• Aircraft will use 2.4 GHz f or control of the aircraft, and for sending data

with defined and tested lost link procedures

• On board stabilization /GPS /autopilot

I am petitioning for exemption to allow Miles of Grace L.L.C. to operate a DJI Inspire 1 equipped with

- a three

- axis gimbals and using a onboard High

- Def camera. This UA has

a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operato r and to exclude it from Class B , C and D airspace including a n o

- fly zone feature. The Inspire 1 also has the fail

- safe function of the autopilot system

, which m eans if the communication between the Main Controller and

the transmitter is disconnected, the DJI Inspire 1 is automatically commanded by its

onboard solid

- s tate electronics to return to the takeoff point . If battery reaches a critical level, the aircraft will descend and land at the current location. Control of the aircraft is maintained during descent to allow the PIC to guide it to a safe landing.

GROUN D CREW

• Pilot in Command (PIC). The pilot in command wil l have at minimum a private pilot

license and a valid third class medical.

• Camera Operator (optional). The Camera operator controls the camera onboard the aircraft for photography and videogra phy missions.

• Visual Observer (VO). The visual observer will provide additional situational awareness during flight operations.OPERATIONAL PARAMETERS 1) The UAS wi ll weigh less than 40 pounds. 2) Flights will be operated within visual line of sight of a pilot and/or observer. 3) Maximum total flight time for e ach operational flight will be approximately 1 5

minutes. Flights will be terminated at 20 % battery power. 4) Flights will be operated at an altitude of no more than 4 00 feet (91.4 meters)

AGL. Unles s a specific COA is obtained, the limit will be according to the “blanket” COA of 200 feet (61 meters). Typical operations are at or below the tree canopy level and within the bounds of the owner’s property. 5) UAS pilot will be an FAA licensed airman with a t least a private pilot’s certificate

and third class medical. PIC will have completed operator and safety training

from Miles of Grace L.L.C . PIC will also have accumulated and log ged at least 30

hours total time as a UAS rotorc raft pilot including at lea st 15 hours logged as a UAS pilot with a multi

- rotor UAS and 5 hours in the same make and model of UAS propose d under this exemption request

. 6) Permission will be obtained from the property owner. 7) Pilot and observer will be able to communicate by voice at all times during the operation. 8) The UAS will only be operated during daytime hours in VFR weather conditions. 9) Operations may not be conducted aboard a moving device or vehicle. 10) Maximum speed 4 0 knots.

PRE

- FLIGHT CHECKLIST

High reflective vest (ora nge or green) worn at all times by entire ground crew 1) Weather conditions are suitable for VFR flight and wind is 20 knots or less. 2) Measure battery voltage to make sure batteries are sufficiently charged before

takeoff. 3) Verify that all wiring connections are tight. 4) Inspect rotor arms for cracks, damage, and loose hardware. 5) Check to make sure propellers are secure and free from dirt, cracks and chips. 6) Install main battery 7) Verify all switch positions on the RC transmitters. 8) Turn on radio control transmi tters and video equipment. 9) Ensure current firmware 10) Calibrate compass in accordance with DJI manual 11) Calibrate IMU’s in accordance with DJI manual 12) Do not initiate takeoff wit h a lock of less than 6 satelli tes

. 13) Announce your intention to take off by ann ouncing “ Take Off ”.

Maintenance specific

The current 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 paragr aph (c) of this section have discrepancies repaired asprescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with part 43. Given that the sections and Part 43 apply only to aircraft with an ai rworthiness certificate, these sections will not apply to the Petitioner. Maintenance will be accomplished by the operator pursuant to the DJI Inspire 1 Owner’s Manuals. An equivalent level of safety will be achieved because these small UAS are very limit ed in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS can land immediatel y. The P.I.C. will ensure that the UAS is in working order prior to initial flight, perform r equired maintenance and keep a log of any maintenance performed. The FAA issued exemption to these regulations in Exemption No. 11062 , &11977

.

Conclusion As pointed out in this application, the SUAs which our company would use, under authorization by t he US DOT

- FAA, are small, light

- weight devices operated within the line of sight of the Pil ot

- in

- Command (PIC), less than 3 00 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location

with aviation ac tivities, unless the air traffic control authorities (ATC) have been notified and have authorized each flight within a radius of this distance.

All our SUAs have proven capability for controlled flight. They are devices offered for general sale on the mar ket around the world and have often been used as Model

Aircraft in the USA. We a re certain that the studies conducted until now by the FAA, about Section 332, Public Law 112

- 95, 2014, have already provided you with the

assurances on the airworthiness of S UAs such as ours.

For the reasons given above , the exemptions requested herein should be granted and

Miles Of Grace L.L.C should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessa ry and appropriate by the FAA. The submission of this application and its contents is the best

demonstration that indeed it is possible t o pursue the authorization proc ess so that some SUAs may be used for legitimate commercial activities and under reasona bly safe

conditions.

Respectfully Submitted,

Peter J

. Greer

Miles of Grace L.L.C.

10607 Direct River Drive Coon Rapids, MN 55433