Joseph Pevey

1282 Glendale Place Gulfport, Mississippi 39507 (228) 297

- 2403 Jomar3385@aol.com Dear Sir or Madam: This petition is being submitted on my behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) , and 14 C.F.R. Part11, Joseph Pevey, a freelance multimedia producer, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to all ow operation of a Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption would permit Joseph Pevey to pursue his commercial interests in providing services to cli ents using a small advanced sUAS in the following areas: Real Estate, Marketing, Land Management/Surveying, Bu ilding or Infrastructure Inspection and Special Events. Joseph Pevey states that all sUAS flights will occur over private or controlled access property and will do so with the property owner's consent and knowledge and that only people who have consented or otherwise have agreed to be within the s UAS’ radius during filming and photography applications. Joseph Pevey has demonstrated the ability to safely and effectively fly the sUAS DJI Phantom 2, DJI Phantom 3 Advanced, DJI Phantom 3 P rofe ssional and DJ I Inspire 1 models which will be used for all commercia l and private purposes. Joseph Pevey complies with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and environmental restrictions or limitations in reference to the operations of sUAS. All flights will occur in ordinance with any state or local laws regarding privacy. I, Joseph Pevey, am seeking the exemption because I am committed to complying with all of the rules, guidelines, limitations, and future legisla tion set forth by the FAA. I agree to operate the sUAS in the manner that I have described, and for the purposes that I have described. Without the exemption request granted, I would be unable to safely and effectively run my business, and it is my intenti on to comply with the FAA and obtain an exemption of the following regulations. The following contains my list of regulations from which I am seeking exemption, and a complete list of responsibilities I assume as operator; it also contains information reg arding the aircraft, public benefit and safety features, and similar petitions requests granted. **Regulations from which exemption is requested** : 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2)14 C.F.R. 91.109

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) & (b) 14 C.F.R. 91.205(b) 14 C.F.R. 91.215 14 C.F.R. 91.401
- 91.417 I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES 1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2, DJI Phantom 3 Advanced, DJI Phantom 3 P rofessional and DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amen d this exemption. 2. Operations for the purpose of closed

-set motion picture and television filming are not permitted. 3. The s UAS may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the s UAS be operated at airspeeds greater than the maximum s UAS operating airspeed recommended by the aircraft manufacturer. 4. The sUAS must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The sU AS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during fligh t operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the s UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during s UAS operations and made available to the Administrator upon request. If a discrepancy exi sts between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be fol lowed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documen ts to the Administrator or any law enforcement official upon request. The operatormust also present updated and revised documents if it petitions for extension or amendment to this grant of

exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s s UAS Integration Office (AFS −80) may be contacted if quesons arise regarding updates or revisions to the operating documents. 8. Any s UAS that has undergone maintenance or alterations that affect the s UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting furthe r operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to pers ons and property. 9. The operator is responsible for maintaining and inspecting the s UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine the s UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the s UAS, the aircraft is prohibit ed from operating until the necessary maintenance has been performed and the s UAS is found to be in a condition for safe flight. 11. The operator must follow the s UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requiremen ts for the aircraft and aircraft components. 12. Each s UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational , or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate 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. 14. The operator may not permit any PIC to operate unless the PIC meets requirements and demonstrates the ability t o safely operate the s UAS in a manner consistent with how the s UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flig ht hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience
- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the s UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and exper ience
- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.
15. s UAS operations may not be condu cted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.16. The s UAS may not operate within 5 nautical miles of an a irport 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 symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement w ith that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The s UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. If the s UAS loses communications or loses its GPS signal, the s UAS must return to a pre - determined location within the private or controlled

-access property. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the s UAS to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certifi cate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attac hed COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 23. Documents used by the operator to ensure the safe operation and flight of the s UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the s UAS any t ime the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 24. The s UAS must remain clear and give way to all manned aviation operations and activities at all times. 25. The s U AS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the s UAS and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protecti on and are within 500 feet of the s UAS, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.27. All operations shall be conducted over private or controlled

- access property with permission from the property

owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov
. **SIMILAR EXEMPTIONS** They are similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213
. **Public Benefit and Safety** Unmanned Aircraft System sUAS s are often seen as superior to helicopters as an aerial video gathering platform du e to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety. Joseph F Pevey is petitionin g for an exemption to operate a DJI Phantom 2, Phantom 3 P rofessional and Inspire 1 with a built

- in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from operations wit h in designated Class B, C and D airspace including a no

-fly zone feature. The DJI Phantom 2, DJI Phantom 3 Advanced, DJI Phantom 3 Professional and Inspire 1 also has a fail

- safe function that is triggered in the event communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and land manually. Joseph Pevey is dedicated to the safe operation of sUAS by insuring proper safety protocols are implemented and followed, with emphasis on the safe operational parameters set forth by the manufacture of the sUAS and the FAA.

Respectufully Submitted for your consideration, Joseph Pevey 1282 Glendale Pl ace Gulfport, MS. 39507 Jomar3385@aol.com 228
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