# JERRYARNOLD 

# PHOTOGRAPHY

1426 victoria blvd  rockledge, fl 3295 5  321.328.8962  jarnold88@cfl.rr.com 

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

RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to the Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Act"), Jerry Arnold (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks

an exemption from the Federal Aviation Regulations ("FARs") to allow for commercial operation for aerial imaging and video for regional tourism, hotels, resorts and real estate

As described herein I, Jerry Arnold, an insured member of thePPA(Professional Photographers of America) am experienced in flying hobby quad

-copters for recreational
purposes. A professional photographer with over 20 years’ experience, I am also an experienced photographer/videographer from both fixed winged aircraft and helicopters and have provided those services for use by hotels, resorts and travel destinations

.

Applicant: Jerry D. Arnold J. Arnold & Associates, Inc. (dba Jerry Arnold Photography)

**Attachments** Yuneec Typhoon 500 4K specifications and safety features
**Regulations from which the exemption is requested:** 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121

14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1)

# JERRYARNOLD 

# PHOTOGRAPHY

1426 victoria blvd  rockledge, fl 3295 5  321.328.8962  jarnold88@cfl.rr.com 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) and (b)
**Extent of relief I seek, and why** **14 CFR Part 21 subpart**  **H** The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, I request exception. In the restricted environment and under the conditions proposed operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without said restrictions.

**14 CFR 45.23 (b)**  Due to the size ofthis UAS it does not have a cockpit, cabin, or pilot station on which tomarket certain words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions would need to be smaller than required minimum. Understanding theimportance of lettering I will mark my UAS with the largest possible letters by placing the word "Experimental" or assigned number or name, based on request/ruling of FAA, on UAS fuselage. The equivalent level of safety will be provided by having the UAS marked on its fuselage as required.

**14 CFR 91.7 (a)**  As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check list prior to each flight an equivalent level of safety will be provided.
**14 CFR 91.9 (b) (2)**  Given the size and configuration, the UAS has no abilityto carry a flight manual on theaircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. Aequivalent level of safety will be maintained by keeping the flight manual at ground control point where the pilot will) have immediate access to it.

**14 CFR 91.103**  As FAA approved flight manuals will not be provided forthe aircraft an exemption will be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances. An equivalent level of safety will be provided by preflight protocol to properly match the machine.

**14 CFR 91.109**  UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size of the aircraft.
**14 CFR 91.113 (a) and (b)**  I can achieve an equivalent level ofsafety as achieved by current regulations because myUAS does not carry pilot or passenger. While helpful, a pilot’s license will not ensure remote control piloting skills.

# JERRYARNOLD 

# PHOTOGRAPHY

1426 victoria blvd  rockledge, fl 3295 5  321.328.8962  jarnold88@cfl.rr.com **14 CFR 91.121**  The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe an exemption may be needed. An equivalent level of safety is achieved by the operator receiving live flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS altitude indicator.

**14 CFR 91.203 (a) and**  **(b)** Similarto, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no abilitytocarry certificate and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately such documents. An equivalent level of safety will be achieved by keeping these documents; to the extent they are applicable to the UAS, at the ground controlpoint where pilot has immediate access to them.

**14 CFR** **91.405 (a),**  **14 CFR** **91.407 (a)**  **(1), 14**  **CFR 91.409**  **(a) (2),**  **14 CFR**  **91.417 (a)**  **and (b)**  Given these sections only apply to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight.
Jerry Arnold is seeking relieffrom all FARs above preventing applicant from conductingaerial photography and video of real estate taken at levels less than 400ft, at a speed lessthan 50 mph, and with a maximum flight time of 18 minutes,. The drone to be used is a Yuneec Typhoon 500 4K. At 60 ounces including battery, the weight of the UAS meets the definition of "small unmanned aircraft" found in section 331 "The Reform Act". In order to obtain high quality photographyand video the UAS will be used at speeds less than its top speed of50 mph. Due to the UASbeing battery powered there are no combustible fuels onboard. Maximum flight time for thisparticular UAS is 18 minutes battery life, flights to be terminated with 25% battery life remaining . Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized I find this exception to be reasonable with an equivalent, or greater, level of safety to be reached by theoperator

. **Saftey** *Please see attachment "Typhoon" for safety features. Asidefrom following all safety features including maximum 400’ altitude, 5 mile limit when flying near airports, I was given a hands on training course when I purchased my UAS.

**Ad ditionally** **:** I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the airport manager has been made. I land my UAS prior to manufacturer recommended minimum level of battery power I pilot my UAS through remote control by line of sight My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and then slowly lands if communication with the remote control pilot is fost I actively analyze flight data and other sources of information to constantly update and enhance safety protocol’s. I conduct extensive pre-flight inspections and protocol, during which safety carries primary importance. I always obtain all necessary permissions prior to operation; and,

# JERRYARNOLD 

# PHOTOGRAPHY

1426 victoria blvd  rockledge, fl 3295 5  321.328.8962  jarnold88@cfl.rr.com I have procedures in place to abort flights in the event of safety breaches or potential danger.

**Public Interest**  The use of an UAS in tourism provide businesses and local governments with a much lowercost solution to highlight aspects of their businesses and communities in turn generating more visitors. UAS in the real estate industry provides both buyers and sellers a higher level ofservice. For a buyer a higher level of marketing and advertising is achieved, appealing to more buyers, resulting in a quicker sale of their home. Quicker home sales also help accelerate the economy as a whole. Buyers experience the benefit of encompassing a whole property, sometimes several acres, in one photo or a short video. Not only does this benefitthe specific home seller or home buyer, but it benefits the general public because it is muchmore efficient than traditional ways of using a plane or helicopter to achieve the same result.We can now provide this level of service while being conservative with fuel, time, emissions,noise, and other resources. Considering size, weight, speed, and absence ofcombustiblefuels
, my UAS will pose much less of a safety concern for the general public when comparedto larger manned aircraft.
Thank you for yourconsideration

.

Jerry Arnold