1

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012, Pub. L.No. 112

-95 (2012), 126 Stat. 11, the FAA’s general exemption authority under 49 USC § 44701(f), and 14 CFR § Part 11, Wayford W. Shrum, (Petitioner) , a professional aviator and owner of small Unmanned Aircraft Systems , hereby petitions for exemptions from 14 CFR Part 21, Subpart H (Airworthiness Certificates), 14 CFR §§ 45.23(b), 61.113(a)&(b) , 91.7(a), 91.9(b)(2), 91.103(b)(1), 91.119 (b) &(c), 91.121, 91.151 (b), 91.203(a) &(b), 91.405(a), 91.407(a)(1)&(2), 91.409(a)(1)&(2), and 91.417(a)&(b). If granted, the proposed exemptions would allow Petitioner to conduct commercial UAS flight operations in aerial photography

and videography in areas of, but not limited to; real estate, wind farm, cell tower and bridge inspections, agriculture, volunteer search and rescue, and, disaster damage assessment. All flight operations will be conducted under the conditions outlined herein and as may be established by

the FAA in granting the above proposed exemptions. This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012 (the ‘Reform Act’). This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may

operate safely

in the National Airspace System (NAS) before completion of the rulemaking required under Section 333 of the Reform Act. In making this determination, the Secretary of Transportation is required to determine which ty pes of UAS's do not create a hazard to users of the NAS or the public or pose a threat to national security in respect to the UAS's size, weight, operational capability, speed, operation in close proximity to airports and populated areas and operation within visual line of sight of the pilot/operator.

**N AME AND ADDRESS OF PETITIONER**  Wayford W. Shrum 2305 Starshine Corpus Christi, TX 78414 (361) 992

- 5494 Point of Contact for this PETITION Richard R. Garza DRONE AVIATION SOLUTIONS, LLC 711 N. Carancahua Suite 1818 Corpus Christi, TX 784012

**BACKGROUND AND INTERESTS**  **OF PETITIONER** Wayford W. Shrum, Petitioner, is a professional aviator of over 41 years and holder of a private airman’s certificate

. His experience as a pilot, flight engineer, A&P examiner, (large) UAS sensor operator/instructor, ultralight, and RC fixed and rotor

-wing pilot will provide for a safe and seamless transition f rom hobby

to commercial UAS operations. Petitioner’s knowledge, skills and experience in UAS operations in the NAS further support granting of this request. If granted, this exemption will permit Petitioner to operate the DJI Phantom Vision 2+ and DJI Inspire 1 multi

-rotor copters , referred to as Petitioner’s UAS, commercially in aerial imaging in areas such as construction sites, real estate, wind (turbine) farms, cell tower, pipeline, and bridge inspections , search and rescue and disaster damage asses sment

. Both drones weigh less than the 55 lbs. that define a small UAS (sUAS )

.

**ABOUT THE UAS DJI Phantom 2 Vi** **sion+ UAS and DJI Inspire 1 UAS** Petitioner seeks an exemption to commercially operate two models of UAS. Both, the DJI Phantom 2 Vision+ and the DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with Ground Control Stations (GCS) utilizing electronic tablet or smart phone systems. Both are equipped with camera systems for the intended aerial photography and videography.
• The DJIPhantom 2 Vision+ has a maximum gross weight of approximately 2pounds 11 ounces, while having a length of 16 inches , width of 16 inches, height of 11.9 inches, and a maximum no-wind airspeed of approximately 54 knots (33.6 mph)

. • The DJI Inspire 1 has a maximum gross weight of approximately 6pounds 8 ounces, while having a length of 17.2 inches, width of 17.8 inches, and a maximum no-wind speed of 79.2 knots (49.2 mph)

. • Both Aircraft are equipped with four main rotors driven by Lithium Polymer battery powered electric motors. The Petitioner’s UAS’s will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 CFR Part 47, Aircraft Registration

. Specific operational data on the UAS is contained in DJI product manuals and is available on request for both, the DJI Phantom Vision 2+, and the DJI Inspire 1.

**SPECIFIC REGULATIONS FROM WHICH RELIEF IS SOUGHT**  Petitioner seeks exemption from the requirements of ; 14 CFR § 45.23 (b)3

14 CFR § 61.113(a)&(b) 14 CFR § 91.7(a) 14 CFR § 91.9(b)(2) &(c) 14 CFR § 91.103(b)(2) 14 CFR § 91.119(b)&(c) 14 CFR § 91.121 14 CFR § 91.151(b) 14 CFR § 91.203(a)&(b) 14 CFR § 91.405(a) 14 CFR § 91.407(a)( 1) 14 CFR § 91.409(a)( 1)&(2) 14 CFR § 91.417(a) &(b)

**1. Petitioner**  **Seeks Exemption**  **from the**  **Requirements of**  **Section 45.23 (b)**  Section 45.23, entitled Display of marks, general. (b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally

certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable. **2. Petitioner**  **Seeks Exemption**  **from the**  **Requirements of**  **Section 61.113(a)**  **and (b).** 

Section 61.113 , entitled Private pilot privileges and limitations : Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employ ment if

— (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property for compensation or hire.4

**3. Petitioner**  **Seeks Exemption**  **From The**  **Requirements Of**  **Section 91.7(a).**  Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition. **4. Petitioner**  **Seeks Exemption**  **From The**  **Requirements Of**  **Section 91.** **9(b)(2) and (c)**  **.** Section 91. 9 , entitled Civil aircraft flight manual, marking, and placard requirements

. (b) No person may

operate a U.S.

-registered civil aircraft

— (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, mar kings, and placards, or any combination thereof. (c) No person may

operate a U.S.

-registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

. **5. Petitioner**  **Seeks Exemption**  **From The**  **Requirements Of**  **Section 91.103(b)(2)**  **.** Section 91.103 , entitled Preflight action states the following, in part: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. **6. Petitioner**  **Seeks Exemption**  **From The**  **Requirements Of**  **Section 91.119 (b) and (c)**  **.** Section 91.119 , entitled Minimum safe altitudes: General, states the following, in part: Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes: (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly

of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.5

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. **7. Petitioner**  **Seeks Exemption**  **From The**  **Requirements Of**  **Section 91.121.**  Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MS L, to

-- i. The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or iii. In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

**8. Petitioner**  **Seeks Exemption**  **From The**  **Requirements Of**  **Section 91.151(b).**  Section 91.151, entitled Fuel requirementsforflight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes

. **9. Petitioner Seeks Exemption from**  **the Requirements of Sections 91.203(a) and (b).** Section 91.151, entitled Civil aircraft: Certifications required, subsection (a) and (b), states the following: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy o f the applicable operations specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing6 that portion of the operations specif ications issued under §21.197(c), or an authorization under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district office. (2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in §47.31(c), or a registration certification issued under the laws of a foreign country

. (b) No person may

operate a civil aircraft unless the airworthiness certificate required by

p aragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

**10. Petitioner**  **Seeks Exemption**  **From The**  **Requirement Of**  **Section 91.405(a).**  Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that 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

. **11. Petitioner**  **Seeks Exemption**  **From The**  **Requirements Of**  **Section 91.407(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a) ( 1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter. **12. Petitioner**  **Seeks Exemption**  **from the**  **Requirements of**  **Sections 91.409(a)(1)**  **and (** **2).** Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

--7 (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

**13. Petitioner**  **Seeks Exemption**  **from the**  **Requirements of**  **Sections 91.417(a)**  **and (b).**  Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- i. A description (or reference to data acceptable to the Administrator) of the work performed; and ii. The date of completion of the work performed; and iii. The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: i. The total time in service of the airframe, each engine, each propeller, and each rotor. ii. The current status of life

-limited parts of each airframe, engine, propeller, rotor, and appliance. iii. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. iv. The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

v. The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.8 vi. Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a) (2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

**E XTENT TO WHICH RELIEF IS SOUGHT**  **1. Extent**  **Of Relief**  **Petitioner Seeks**  **And The**  **Reason Petitioner**  **Seeks Relief**  **from Section**  **45.2 3**  **(b).** Relief from Section 45

. 23 (b) entitled Display of marks, general is requested due to the size of the UAS and absence of a cabin, cockpit or flight station, which physically limits the location and prescribed size of the markings. **2. Extent**  **Of Relief**  **Petitioner Seeks**  **And The**  **Reason Petitioner**  **Seeks Relief**  **from Section**  **61.113(a) and**  **(b).** Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employ ment if: (1) The flight is only incidental to that business or employ ment; and, (2) The aircraft does not carry passengers or property for compensation or hire. Petitioner submits that all flights of the DJI Phantom Vision 2 + and Inspire 1 UAS, conducted by the Petitioner pursuant to the grant of this Petition: (1) will be completely and deliberately related to Petition’s business; and (2) will not carry passengers or property for compensation or hire.9

As set forth more fully below, Petitioner submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom Vision 2 + and Inspire 1 UAS unless that PIC has met certain flight

-hour and currency requirements, demonstrating to Petitioner that the PIC is able to safely operate either the DJI Phantom Vision 2 + and Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.
**3. Extent**  **Of Relief**  **Petitioner Seeks**  **And The**  **Reason Petitioner**  **Seeks Relief**  **From Section**  **91.7(a).** Relief from Section 9 1.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Petitioner to determine that the DJI Phantom Vision 2 + and DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Petitioner ’s DJI Phantom Vision 2 + and Inspire 1 User, Maintenance and S afety Manuals). Petitioner seeks the requested relief because the DJI Phantom Vision 2 + and Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Petitioner will ensure that, prior to every flight, the DJI Phantom Vision 2 + and Inspire 1 UAS are i n airworthy condition based on the requirements for safe flight in the operating documents (i.e., Petitioner ’s DJI Phantom Vision 2 + and Inspire 1 User, Maintenance and Safety Manuals)

. **4. Extent**  **Of Relief**  **Petitioner Seeks**  **And The**  **Reason Petitioner**  **Seeks Relief**  **From Section**  **91.9 (b)(2) .**  Relief from Section 91.9, titled Civil aircraft flight manual, marking, and placard requirements is requested because the UAS size and configuration has no place to carry a flight manual in the aircraft where there is no pilot on board, nor is there room or capacity to carry such an item. The equivalent level of safety will be maintained by making the User Manual easily accessible to the PIC at all times during flight operations. **5. Extent**  **Of Relief**  **Petitioner Seeks**  **And The**  **Reason Petitioner**  **Seeks Relief**  **From Section**  **91.103(b)(2 )**  Relief from Section 91.103, titled Preflight actions is requested as the UAS does not require runway nor airport information for takeoff and landing of the UAS. The UAS does not require use of an airport or runway, rather it can takeoff and land from a field, parking lot, driveway, back yard, etc. In addition, the pilot will perform preflight actions in accordance with the User Manual, review safety checklists and weather conditions, and become familiar with the sur rounding area prior to flight. Any discrepancy in flight hardware, software or flight conditions found to be unfavorable for flight will require the flight to be aborted

. Flight operations will not resume until any hardware, software, physical obstacles, weather, or other10

unsafe issues are addressed to provide for safe flight. These actions will provide an equivalent level of safety

. **6. Extent**  **Of Relief**  **Petitioner Seeks**  **And The**  **Reason Petitioner**  **Seeks Relief**  **From Section**  **91.119(b) and (c) .**  Relief from Section 91.119 (b) & (c) titled Minimum safe altitudes is requested due to the fact that; (b) to be effective, commercial flight operations performed by Petitioner will require close

proximity imaging at distances closer than 2,000’ and lower than 1,000’ AGL, and (c) most commercial flight operations by the Petitioner will occur at or below 400’ AGL, or as authorized in the Exemption and any related COAs. An equivalent level of safety will be achieved by engaging the property

owners/agents for authorization prior to any flight operation. Additionally, the (small) size, speed and mass of the Petitioner’s UAS is incapable of causing damage to people or property when compared to a manned aircraft performing a similar function

. **7. Extent**  **Of Relief**  **Petitioner Seeks**  **And The**  **Reason Petitioner**  **Seeks Relief**  **From Section**  **91.121.** Relief from Section 91.121, entitled Altimeter settings, is requested to allow flight operations of the DJI Phantom Vision 2 + and Inspire 1 UAS , both of which have no altimeter, and which utilize GPS equipment and a telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). An equivalent level of safetyi s achieved as the UA’s GPS

-derived altitude is set on the ground to zero feet AGL as part of every pre-flight. **8. Extent**  **Of Relief**  **Petitioner Seeks**  **And The**  **Reason Petitioner**  **Seeks Relief**  **f rom**  **Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom Vision 2 + and Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR). Since Petitioner’s UAS are battery

-powered, with a maximum flight endurance not exceeding 2 3 minutes , the requirement of Section 91.151(b) becomes impractical. Without relief as requested, the useable flight time of the battery powered DJI Phantom Vision 2 + and Inspire 1 UAS will severely limit the practicality of the proposed aerial imaging flight operations as described in this Petition.

**9. Extent**  **Of Relief**  **Petitioner Seeks**  **And The**  **Reason Petitioner**  **Seeks Relief**  **f rom**  **Section 91.203(a) and**  **(b).** Petitioner seeks relief from the provisions of Section 91.203 entitled Civil aircraft: Certifications required regarding airworthiness certificates. Given the size and limited operating area(s) proposed under the Exemption request, the DJI Phantom Vision 2 + and Inspire 1 UAS make it11

unnecessary

to proceed with the certificate of airworthiness process as established in Part 21, Subpart , entitled Airworthiness Certificates

. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS involved. An analysis of these different criteria demonstrates that the Petitioner’s UAS operated without an airworthiness certificate, under the conditions proposed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness certificate. **10. Extent**  **of Relief**  **Petitioner Seeks**  **and the**  **Reason Petitioner**  **Seeks Relief**  **from Sections**  **91.405(a), 91.407(a** **) ( 1),**  **91.409(a ) (** **1) &**  **(a ) (** **2), and**  **91.417(a) &**  **(b).** Since Sections 91.405(a), 91.407(a) ( 1), 91.409(a) ( 1) & (a) (2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Petitioner requests relief from these Sections because the DJI Phantom Vision 2 + and Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom Vision 2 + and Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Petitioner will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Petitioner ’s DJI Phantom Vision 2 + and Inspire 1 User, Maintenance and Safety Manuals).

**HOW WILL THIS GRANT BENEFIT THE PUBLIC AS A WHOLE** Granting the present Petition will further the public interest by allowing Petitioner to safely, and economically perform aerial video and photography o f construction sites, real estate, events and civic landscape over certain areas of the United States. Additionally, use of the Petitioner’s UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Further, the benefits of Petitioner ’s proposed operation of the DJI Phantom Vision 2 + and Inspire 1 UAS will be realized without implicating any privacy issues. **1. The**  **Public Will**  **Benefit f**  **rom Decreased**  **Congestion o** **f t** **he NAS.**  The DJI Phantom Vision 2 + and Inspire 1 UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery

. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of Petitioner’s UAS would reduce the numbers of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.12

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports and subsequent ATC workload will be reduced. The Petitioner’s UAS do not require an airport to takeoff or land. **2. The**  **Public W** **ill Benefit**  **f rom**  **t he**  **Safety a** **nd Efficiency**  **o f**  **t he**  **DJI Phantom Vision 2 + and**  **Inspire 1 UAS.** Conducting aerial acquisitions with the DJI Phantom Vision 2 + and Inspire 1 UAS, instead of manned aircraft, will benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the Petitioner’s UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are ty pically utilized for aerial video and photography, while burning approximately 20

-30 gallons per hour of leaded aviation fuel. The Petitioner’s UAS , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom Vision 2 + and Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom Vision 2 + and Inspire 1 UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground and in the air in contrast to a manned aircraft. **3. Performing**  **Aerial Video**  **and Photography**  **Operations w** **ith the**  **DJI Phantom Vision 2 +**  **and Inspire 1 UAS**  **w ill**  **Benefit t** **he Economy.**  In addition to being safe and efficient, the DJI Phantom Vision 2 + and Inspire 1 UAS are an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom Vision 2 + and Inspire 1 UAS will allow business ventures , as Petitioner ’s , to remain competitive and contribute to the economic growth of the U.S. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom Vision 2 + and Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but also provides the flexibility without the high operational cost of a traditional manned aircraft. By operating small UAS such as the DJI Phantom Vision 2 + and Inspire 1 UAS, Petitioner can remain competitive, and provide an economic alternative (to manned aerial data acquisition) to small and large businesses

. This economic aerial imaging alternative will provid e business savings, greater job stability to employees13

and contractors and will lead to increased economic growth for U.S. businesses. In addition, increased local, state, and federal tax revenues may be realized. **4. There**  **Are No**  **Privacy Issues.**  Similar to the manned aerial photographyand data acquisition flight operations that have been conducted for decades, Petitioner ’s proposed operation of the D J I Phantom Vision 2 + UAS and DJI Inspire 1 will not pose a threat to privacy

. Specifically, the DJI Phantom Vision 2 + and Inspire 1 UAS will be operated for commercial purposes with very specific photographic data collection of phy sical structures, land scape, gatherings of people and events, and will require property owner /agent consent and approval as well as local law enforcement notification, and always in accordance with the FAA Exemption and COA requirements and limitations.

**REASONS WHY**  **THE EXEMPTION**  **WOULD NOT**  **ADVERSELY AFFECT**  **SAFETY, OR**  **HOW THE**  **EXEMPTION WOULD**  **PROVIDE AN**  **EQUIVALENT LEVEL**  **OF SAFETY**  The operational limitations and requirements of the UAS, as proposed in this exemption request, provide for an equivalent or higher level of safety due to the size, mass , speed and altitudes when compared to manned aircraft, and also, the piloting certification required in the exemption and COA are equal to those currently required for flight in the NAS. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial UAS flight operations under the FAA issued exemption include:

 The small UAS will weigh less than 55 lbs.
 The UAS will not be operated at a speed exceeding 50 mph.
 The UAS will be operated at an altitude of no more than 400 feet above ground level (AGL).
 Flights will be operated within line of sight of a pilot and/or visual observer.
 Maximum flight time for each operational flight will be less than 30 minutes. Flights will be terminated at 25% battery power reserve.
 The PIC will hold the required FAA airman medical certificate and/or a valid U.S. driver’s license issued by

a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
 The PIC will obtain verbal/written consent of all persons involved with the planned operation and ensure that only

consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the Operator’s Manual

. With the advanced permission or direction of the FSDO, operations at closer range may be approved.14

 The PIC will have been trained in the operation of the small UAS prior to exercising PIC duties under this exemption.
 The PIC is responsible for maintaining the UAS to ensure that it is in a condition for safe operation.
 A pre-flight inspection will be performed by the PIC to ensure that the UAS is in a condition for safe flight.
 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.
 All operations conducted over private or controlled

-access property will be done with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized agent will be obtained prior to the planned flight

.  If the small UAS loses communications or loses GPS signal, the small UAS ’ identified in this exemption request have the capability to return to a pre-determined location and land autonomously. This is a safety feature of the UAS not found in manned aircraft

.  UAS operations will be aborted if unexpected obstacles, weather, or emergencies are encountered

.  No operations will be conducted at night, as defined in 14 CFR § 1.1.
 All operations will be conducted under visual meteorological conditions (VMC).
 No operations will be conducted within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airports not denoted with an ARP, the center of the airport sy mbol as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder.
 No operations will be conducted at night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC).

**SUMMARY** The following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Petitioner requests exemptions from the following rules: 14 CFR § 2 1, Subpart H; 14 CFR § 45.23 (b); 14 CFR § 45.25; 14 CFR § 45.27; 14 CFR § 45.29; 14 CFR § 61.113 (a) and (b); 14 CFR § 91.7 (a); 14 CFR § 91.9(b)(2) & (c); CFR § 91.103 (b)(2) ; 14 CFR § 91.119 (b) & (c) ; 14 CFR § 91.121; 14 CFR § 91.151(b); 14 CFR § 91.203(a) & (b); 14 CFR § 91.405 (a) ; 14 CFR § 91.407 (a)(1); 14 CFR § 91.409 (a)(1) & (2); and, 14 CFR§ 417 (a) & (b)

. Petitioner seeks an exemption to conduct commercial sUAS flight operations in aerial photography and videography in areas of, but not limited to, real estate, wind farm, cell tower and bridge inspections, agriculture, volunteer search and rescue, and, disaster damage assessment. **CON CLUSION** 15

Wayford W. Shrum’s Petition for Exemption satisfies the criteria set forth in the FMRA, and further, Mr. Shrum’s proposed operations would benefit the public and pose no threat to national security. The proposed operations described in this Petition for Exemption are similar to those in previously

issued grants of exemptions, and it is desired that the FAA grant the requested exemptions allowing Mr. Shrum to operate a UAS commercially to perform aerial photography and videography. Thank you in advance for your consideration.

Respectfully

submitted,

Wayford W. Shrum