1

US Department ofTransportation Federal Aviation Administration 800 Independence Ave S.W. Washington, DC 20591 Dear Sir or Madam: Justin William Mulcahey is submitting this petition on his own behalf, without legal counsel or consultation, in accordance with the terms set forth in Section 333 ofthe FAA Modernization and Reform Act of 2012 (“Reform Act”) and 14 C.F.R. Part 11. Justin W Mulcahey requests an exemption from the Federal Aviation Regulations (“FARs”)described below as they pertain to the operation ofsmall Unmanned Aerial Systems (“UAS”). Justin W Mulcahey is seeking said exemptions to commercially operate his small UAS within the National Airspace System (NAS) for the purpose of providing real estate photography as well as commercial aerial videographyand photography services. All flight operations will be performed by a two
-person flight team and will be conducted in accordance with Section 333 ofthe Reform Actas set forth by the Federal Aviation Administration (“FAA”).
Pursuant to 14 C.F.R. § 11.81(f), Justin W Mulcahey is providing the following summaryfor publication in the Federal Registerto be included at the discretion ofthe FAA: Petitioner: Justin William Mulcahey Seeking Exemptions from Sections of 14 C.F.R: 14 C.F.R. Part 21, 14 C.F.R.§ 45.23(b), 14 C.F.R. § 61.113(a) and (b), 14 C.F.R. § 61.133(a), 14 C.F.R. § 91.109(a), 14 C.F.R. § 91.119, 14 C.F.R. § 91.121, 14 C.F.R. § 91.151(a), 14 C.F.R. § 91.203(a) and (b), 14 C.F.R. § 91.215, 14 C.F.R. § 91.401through 91.417, 14 C.F.R. § 91.7(a) and (b). Description of ReliefSought: Justin W Mulcahey is requesting an exemption from sections ofTitle 14 ofthe Code of Federal Regulations to operate small (55 lbs. gross weight or less) unmanned aircraft systems under the control of licensed private pilots. My petition is very similar in scope to the exemption granted to Astraeus Aerial under Exemption No. 11062 (Regulatory Docket No. FAA

-2014

-0352) and the associated Summary Grants (Regulatory Docket Nos. FAA

-2014

-0353, FAA

- 2014

-0354, FAA

-2014

-0356, FAA

-2014

- 0357 and FAA

-2014

-0358). Where applicable, Justin Mulcahey will adhere to the terms set forth in the Astraeus exemption. When applicable, training, maintenance and operations procedures will be modified/updated to comply with future regulations set forth by the FAA as UAS law is implemented.

The petitioner contact information is: Justin W. Mulcahey 212 W 5th Ave Apt 1032

Ellensburg WA 98926 Phone: (253) 459

-9891 Email: justin.mulcahey@me.com Justin W Mulcahey is requesting exemptions from the followingregulations:

14 C.F.R. Part 21 14 C.F.R. § 45.23(b) 14 C.F.R. § 61.113(a) and (b) and 14 C.F.R. §61.133(a) 14 C.F.R. § 91.109(a) 14 C.F.R. § 91.119 14 C.F.R. § 91.121 14 C.F.R. § 91.151(a) 14 C.F.R. § 91.203(a) and (b) 14 C.F.R. § 91.215 14 C.F.R. § 91.401 through 91.417 14 C.F.R. § 91.7(a) and (b)

**GENERAL RESTRICTIONS**  **AND ASSURANCES**  Using FAA Notice on National Policy N 8900.227, “Unmanned Aircraft Systems(UAS) Operational Approval” and Exemption No. 11062 as guidance, Justin W Mulcahey will document and implement policies and training to ensure compliance with N 8900.227 Section14 “Operational Requirements for UAS” and including the following restrictions: (a.) All flight operations will be performed by a minimum oftwo (2)

individuals: a Pilot in Command (PIC) and a Visual Observer(VO). (b.) PIC will conduct a pre-flight briefing with VO and client or their designee to review flight profile, safety considerations and emergencyprocedures. (c.) PIC will perform a pre-flight inspection ofthe UAS that includes:the communications link between the UA and ground control station, remaining battery charge, condition of airframe, propellers and wiring. (d.) During flight, PIC and VO will maintain direct communications and terminate flight operations ifthey are no longer able to communicate with each other. (e.) Unmanned Aircraft (UA) shall not exceed 55 pounds gross vehicle weight (including any attached cameras, gimbals or other equipment). (f.) All flight operations will take place in Class G airspace no further than 3⁄4 nm from the PIC, below 400 feet AGL and at airspeeds less than 25kts.3 (g.) All flight operations will take place under VFR conditions within visual line of sight (VLOS) ofthe PIC. No flight operations will take place atnight. (h.) Flight operations will not be conducted over densely populated areas, heavily trafficked roads, at an air show or other environment that may include other low

- flying aircraft. (i.) No flight operations will be conducted over an open-air assembly of people unless a comprehensive safety plan can be implemented to mitigate riskof injury to individuals or damage toproperty. (j.) Flight operations will be terminated when the UA battery reaches a remaining charge of25%. Additional information regarding General Flight Operations, PIC and VO qualifications may be found in AppendixA: Justin W Mulcahey Equipment and Flight Operations Overview

**BENEFIT TO**  **THE PUBLIC** 
The requested exemptions will allow Justin W Mulcahey to operate his UAS to provide real estate photography, commercial photography and videography services to his clients. In addition toadvancing the “safe and expedient integration of UAS into the NAS” as mandated by the FAA Modernization and Reform Act of 2012, Public Law 112

- 95 (P.L. 112

-95), grantingthe requested exemption is in the public interestas: 1. A UAS generates less pollution from exhaust, has a lower noise signature and requires a substantially smallerto footprint from which to operate, making it more cost
-effective and environmentally friendlythan full size, mannedfixed

-wing aircraft and helicopters. 2. A UAS uses either an electric power source or a significantly smaller amount offlammable fuel than a manned aircraft, making it a safer platform than itsmanned counterparts. The UAS described herein are also more maneuverable and provide a greater safety margin at the speeds and altitudes required foraerial cinematographythan full size fixed

- or rotary
wing aircraft. 3. When properly operated within the regulations set forth by the FAA, a UAS can be less disruptive to the NAS than its full

-sized counterparts because it doesnot require airports/runways, fueling apparatus or other infrastructure required by manned aircraft.
Thank you for time and consideration ofthis petition. Please contact me ifyou require any additional information to process this request.4

Sincerely, Justin William Mulcahey

Attachments: Appendix A: Equipment and Flight Operations Overview5 **APPENDIX A:**  **EQUIPMENT AND**  **FLIGHT OPERATIONS**  **OVERVIEW Unmanned**  **Aircraft Systems**  **(UAS)** The Unmanned Aircraft (“UA”) being used is built by an experienced manufacturer and maintained due to manufacturer’s recommended maintenance The UA design allows Justin W Mulcahey to deploythe best equipment to remain as least disruptive to the NAS and surrounding environment. The following data summarizes the UA being used: **DJI Inspire**  **1 PRO**  **Quadcopter Model** : T601 **Unloaded Weight:**  6.32 lbs **Loaded Weight:**  7.50 lbs **Max Speed:**  18 m/s
**Motor Model:**  DJI 3510H **Propelle r**  **Model:** DJI 1345T **Dimensions:** 17.24 x 17.76 x 11.85 in. **Diagonal Distance:**  22.01 to 22.87 in. **Battery:** LiPo (4500 mAh, 5700 mAh) **Working Environment**  **Temperature:** 0° to 40° C
**Flight Team**  **Memebers** The flight team will including the following individuals for ALL events: 1. A Pilot in Command (PIC), whose primary responsibilitywill be the safe operation of the UAS in accordance with the FARs. 2. A Visual Observer (VO), who will be responsible for ensuring that the UASis being operated within the restrictions set forth in the FARs and to providea second pair of eyes to mitigate any hazards to safe operations. The VO will receive orientation on the FAR and training on the responsibilities of an observer such as, but not limited to, flightteam communications, properly monitoring the airspace and identifying hazards. 3. (Optional

– if required and on a project

-by

-project basis) A Camera6 Operator, (CO) who will operate any still or video camera included in the UAS. The CO is not considered a part ofthe flight team, but will be used when a project requires a moving camera instead of one that it locked in a fixed position, or ifterrain, proximityto non-Class G airspace or other environmental factors makethe addition of a third team member prudent. **Flig ht**  **Team Qualifications**  **and Responsibilities**  Each member ofthe flight team will meet a minimum set of qualifications, including training and licenses to ensure team and public safety is kept at the highest priority. During operations, flight team members will be responsible for specific tasks to divide the workload and further enhance safety. Pilot in Command (PIC) The PIC holds the proper licenses/certifications to conduct the flight and hasfinal authority over all operations (regardless if UA is in the air at the time) and responsibility for safely operating the UA. A PIC will be designated prior to flight operations and only one person will be the designated PIC at anytime.
At minimum, the PIC will possess thefollowing:

1. FAA Private Pilot License and required medical certifications 2. The PIC will be qualified to operate the UA by possessing no less than ten hours logged as a UA pilot with a similar UA type. 3. Successful completion oftraining on the properpre-flight inspection of UAs. The PIC’s duties include:

1. Evaluating the environment for hazards 2. Performing pre-flight checks and briefings 3. Safely operating the UA within the FARs 4. Coordinating with the VO to evaluate the operating area for safety 5. Terminating flight operations and landing the UA as soon as practicaland safe to do so if unsafe conditions arise.
Visual Observer (VO) The VO is responsible for overseeing the safety aspects of UAS operations oneach project and enforcing all FAA regulations set forth in the ReformAct.
At minimum, the VO will demonstrate knowledge ofthe requirements defined in 14 C.F.R. including: operations near other aircraft, right

-of

-way and basic VFR, plusthe proper use of pilot/air traffic control phraseology. VOs who are not licensed private pilots must be able to demonstrate an understanding ofthe following:

The VO fully understands the FARs as they relate to the safe operation of a UAS and the importance of complying with them,7 The VO is familiar with crew resource management and clearly understands his/her role as it relates to the PIC, The VO is able to accurately read and interpret aeronautical charts, NOTAMs, COAs, weather forecasts and any other information required to ensuresafe operations, The VO is able to effectively communicate and coordinate with the PIC to ensure a safe operating environment The VO has the opportunityto gain hands

-on experience with a PIC, before participating on a paid project, to validate knowledge and address any questions or concerns. **Flight Operations** 
Pre

-flight The PIC and VO will conduct a pre-flight briefing thatincludes: Review aeronautical charts to o ensure that planned operating area is compliant with FARs o identify known hazards to navigation o determine safe divert areas (if applicable) Review weather forecasts Review all Notice to Airmen (NOTAM) that may be active in the operating area When required, obtain a Certificate of Waiver orAuthorization (COA) from the regional ATO When required, submit a notice of planned operations to the appropriate Flight Standards District Office (FSDO) a NOTAM between 72 and 48 hours priorto commencing operations Perform a pre-flight maintenance check to ensure that the UAS isfunctioning according to manufacturer specifications including the communications link between the UA and ground control station, remaining battery charge, condition of airframe, propellers and wiring. Inspect the UA to comply with maximum weight limitations of 55 lbs. gross weight Display a sign or other notice indicating that UAS operations are in progressin the area and identifyingJustin W Mulcahey as the owner/operator ofthe UAS. The ground control station is a portable unit that is worn bythe PICto ensure freedom of movement should repositioning be required to maintain proper visual lineof sight. As such, the notification sign will be placed within 10 feet of the PIC’s initial position and moved, as required, and never to exceed a distance of 20feet from the PIC. Additionally, flight operations will primarily be conducted withina closed set environment or in an area where only authorized and consenting individuals are allowed.
In

-flight8

The PIC will operate the UAS in accordance with the FARs and pre-flight briefing described above to maintain public safety. During flight operations, the PIC will: Navigate the UAS within the operational area Monitor altitude and airspeed Maintain visual line of sight (VLOS) with the UA Monitor battery charge/remaining flying time The VO will: Monitor UAS operations to cross-check PIC and ensure that the UA stays within VLOS and within the required altitude and airspeed limitations, Monitor the airspace to ensure that aircraft, birds or other airborne hazards remain out ofthe operating area, Monitor the general operating area to ensure that the UA maintains proper separation from hazards, restricted or unauthorized airspace and that no ground hazards, such as unauthorized persons or vehicle enter, the operating area, Monitor weather conditions to ensure that wind, cloud ceiling or otherfactors do not exceed safe operating parameters Immediately instruct the PIC to terminate flight operations and assist the PIC to safely land the UA if any unsafe conditions arise.