Jeffrey R Barksdale July 12, 2015

31447 Emperor Dr.

Canyon Lake

, California 92587

d

ba , API I nspection, llc

4051 Barrancas Ave.

Suite G, 114

Pensacola, Florida 32507

Office 510.356.5658

Email: dronesailor @gmail.com

U.S. Department of Trans portation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 2059

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

UAS Training References :

1. DJI Phantom 3 Professional Users Manual V1.2

2. DJI Ph antom pilot training gui de V1.1

Exemption References:

1. FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the

petition of DOUGLAS TRUDEAU

2. FAA Exemption No. 11136, Regulatory Docket No. FAA

- 2014

- 0508 in the matter of the

pet i tion of ADVANCED AVIATION SOLUTIONS LLC

3. FAA Interim exemption for “Blanket “ 200 foot COA

Dear Sir or Madam,

The petitioner request that in a manner as described in reference 3, he be granted a “blanket” Certificate of Waiver Authorization for flig hts at or below 200 feet, that weigh less than 55 lbs., op erate

during d aylight VFR conditions, operate within visual line of sight con ditions of the pilots, and stay

certain distances away from airports and heliports.

Also, i n accordance with the FAA’s Guidelines for Su b mitting a Petition for Exemption under section

333 of the FAA Modernization and Reform Act of 2012, Jeffrey R Barksdale dba

API I nspection

, llc, hereafter referred to as the petitioner, requests exemption from the followingsec tions of Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

(a)(1); 9 1.409(a)(2); 91.417(a) & (b)

i n order to operate small unm anned aircraft systems ( UA S ) comm ercially in airspace regulate d by

the Federal Aviation Admini stration (FAA)

. The Petitioner requests this exemption for the purposes of aerial photography, videogr aphy, mapping, cro p surveying, inspections and other flight operations that could be performed safely

and more cost effective with the use of UA S at low altitude within the U.S. national airspace

system as compared to a manned aircraft.

Operations will be performed only with the authorization and permission of clients or

their authorized a gents in order to facilitate commerce an d raise awareness of the beneficial

uses of small unmanned air systems. So long as such operations are conducted within and

under the conditions outlined herein or as may be establis hed by the FAA as required by

Section 333. The conditions identified and proposed by the petitioner are drawn from UA S

references 1 & 2

.

The Federal Aviation Regulations (FARs)

The petitioner seeks exemption from the above

- mentioned FARs for the following reasons;

Section 61.113(a); 61.113(b)

The petitioner requests relief in order to facili tate the utilization of pilots who hold as a minimum

a S p ort P ilot certificate. Any pilot operating under this exemption would be required to c omply

with all conditions as set forth and in a similar fashion to the previously granted exem ptions.

Section 91.119(c)

As referenced in Exemption 11138 (DOUGLAS TRUDEAU), opera tions conducted closer than 500

feet to t he ground may require that the UA S be operated closer than 500 feet to essential pe rsons, or objects that would not be possible wi t hout addition al relief. The petitioner requests

waiver for this condition to allow reason able and responsible operations in but not limited to, areas of

subdiv i sions and neighborhoods if required.

Section 91.121

As referenced in Exemption 11138 (DOUGLAS TRUDEAU ) section 19.121

is inapplicable since the UA S does not have an altimeter and instead utilizes electronic GPS

with a barometric sensor (or ultrasonic sensors when i n doors) for altitude information.Section 91.151(a)

As referenced in Exemption 11 136 (ADVANCED AVIATION SOLUTIONS LLC ) prior relief has

bee n granted for manned aircraft to operate at less than the prescribed minimums, including

Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted

in Exemption numbe rs 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides

battery power remaining in percent to the PIC. The UA batteries provide approximately 20

minutes of powered flight. Information provided in the operatin g documents discusses

proc edures regarding remaining battery power management. Those documents contain a

condition in which the PIC will initiate a landing procedure when battery remaining reaches a

spec i fied level. Given the l imitations on proposed operations and the location of proposed operations,

the FAA found that a reduced minimum power reserve for flight in da ytime VFR conditions was reasonable.

Section 91.405(a); 91.407(a)(1); 91.409(a)(1), 91.409(a)(2); 91.417(a); 91.417(b)

As referenced in Exemption 11138 (DOUGLAS TRUD EAU), the petitioner proposes to inspect

and ensure that the UAS is in a condition for safe flight in accordance with the operating

documents. The FAA found that adherence to the petitioner’s operating documents and the

conditions and limitations specified

, describing the require ments for maintenance, inspection,

and record keeping, were sufficient to ensure that safety would not be adversely affected.

UAS ; DJI Phantom 3 Professional

The requested exemption would permit commercial operation o f the DJI Phantom 3 Professio nal

, which is l ess than 5 5 lbs

. and travels at less significantly less than 87 knots, by Jeffrey R Barksdale

dba API I nspec tion, l lc

. Petitioner would perform services that produce high quality still photographs and vid e o s tak en by the

onboard camera and enhance his existing inspection capabilities.

The use of UAS for aerial services reduce s t he need to utilize conventional man ned aircrafts

for the same purpose at a fraction of t he cost, increased efficiency and productivity.

Since the U AS is electric there is an almost 100% decrease in fuel emissions providing significant e nvironme ntal benefits.

Operations under the exemption will be subject to strict operating requirements and

conditions that equal or exceed the equivalent level of s afety to currently authorized oper ations

using manned aircraft.

C onditions may be modified by the FAA as required by Section 333.

The UAS will be operated under controlled conditions at low altitude (200ft or less)

in airspace that is limited in scope, as described herein; it will have autom ated control features,

as described in the referenced manuals.The U AS will be operated by the Pilot in Charge (PIC) who possesses

, as a minimum

, a

Sport Pilot Certificate, a valid US Driver’s License and/ or an FAA issued Airman medical certificate.

Finally, the airspace in which the U AS will ope r ate will be Class G airspace.

Approval of these exemptions would thereby enhance safety and fulfill the Secretary of

Transportion’s(the FAA Administrator’s ) responsibili ties under Se ction 333(c) of the Reform Act to

“ establish requir e ments for the safe operation of such aircraft systems in the national airspace system ”

The petitioner has reviewed FAA exemptions references 1

- 3 Conditions and Limitations section

and agrees that the procedures specified therein are reasonable and will be utilized in order to

ma nage and mitigate risk and ensure public safety. A preflight checklist will be developed and

employed to ensure the UAS airworthiness and will be performed prior to ea ch launch.

Public interest

Use of the UAS’s in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned aircrafts.

Additionally

, use of the UAS in order to facilitate comme rce could lead to economic growth.

Operations for this petition will enable service for business and to obtain detailed info rmation that cannot be displayed through ground level access.

The petitioner will provide clients with photographic data for these p urposes on a

‘ for hire’ basis acti ng as an independent contractor and the PIC. A vis u al observer will be utilized

.

Conclusion

The petitioner request that in a manner as described in reference 3, he be granted a “blanket” Certificate of Waiver Authorizat ion for flig hts at or below 200 feet, weight less than 55 lbs., o p erates during

daylight VFR conditions, operates within visual line of sight conditions of the pilots, and stays certain

distances away from airports and heliports.

The petitioner is requesti ng this exemption for the purposes of “aerial photography, videography,

mapping, s urveyi ng, inspection and other flight operations”.

The primary purpose of seeking this exemption is to obtain the capability to offer those

services while remaining in FAA c ompliance. The petitioner is in the process of obtain ing a

S port Pilot Certificate, h as over 1 0 years of exp erience in RC hobbies with 3 years in UAS aviation.

Respectfully requested and submitted,

Jeffrey R. Barksdale

API I nspection

, llc