David	A.	Kello

REALTOR 1041	Hall	Rd Malabar	FL,	32950 Cell

– 321

- 427

- 4748 Email

– DaveKello@gmail.com

July 16 th , 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey

Ave SE Washington, DC 20590 I, David A. Kello , am writing pursuant to the FAA Modernization and Reform act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, David A. Kello , an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, David A. Kello , may operate a small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”) in accordance with FAA UAS Regulations & Policies. I would like to formally submit for an exemption from the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). To operate the following UAS: DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , Aerosky C17 , and Walkera TALI H500 along the guidelines of the accompanying o perator’s manuals. These UAS will be equipped with detachable cameras and will be transported in proper storage. This proposed exemption would allow me operation of unmanned aircraft systems (UAS) for the purpose of aerial videography/ photography as a ser vice to the public/ business interests. Asfound in exemption No. 11138 (Trudeau), the FAA recently approved similar use

of a Phantom 2 UAS. These devices were selected because they have proven reliable flying capabilities managed by gyro stabilized fligh t, ground detection (phantom 3 and inspire 1) GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning home and prop guards. This will act to further safety protocols exclusive to lightweight UAS’s specific to video and photography usage as I, David A. Kello , record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to assists with future protocol and safety regulations. **Specific section or sections of 14 CF R which I seek relief and the reason I**  **seek relief:** 14 C.F.R. Part 21: Airworthiness Certificates Given the size and limited operating area associated with the aircrafts to be utilized by I, David A. Kello , an exemption from Part 21 meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the reform Act. In all cases, an analysis of these criteria demonstrates that the UA operated without an airworthiness certificate, in the restricted environment and under the conditions p roposed will be at least as safe, or safer, than conventional aircraft operating with an airworthiness certificate without restrictions and conditions proposed. 14 C.F.R. 45.23: Display of marks: general The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain words or phrases. Further, the two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. 14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command The FAA has previously declared that additional manned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previous ly issued exemptions to this regulation through Exemption Nos. 11062 and 11138. 14 C.F.R 91.7: Civil aircraft airworthiness Currently, since there is no certificate applicable to the UAs in question, this regulation is inapplicable.14 C.F.R. 91.9 (b)(2 ): Civil aircraft flight manual, marking, and placard requirements Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this aircraft and given its size, this regulation is inapplicable. An equivalent leve l of safety will be achieved by maintaining a safety/flight manual with the operator. 14 C.F.R. 91.119(c): Minimum safe altitudes I, David A. Kello will ensure that UAS do not operate any higher than 400 feet at ground level. I will not fly over congested areas. I will plan operations before hand, for proper flight safety, and proper height analysis as to avoid collisions. 14 C.F.R. 91.121: Altimeter settings The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety will be achieved by using this. 14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions The UAS that I will fly are powered by electricity, using lithium polymer batteries that currently have a flight limit of approximately no more than 20 minutes. Therefore, due to the limitations of the batteries, it is currently impossible to comply with part 91.151. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. I, David A. Kello , however will always fly safely while having the manuals with me at all times during operation

. 14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. However I, David A. Kello , will perform preflight inspections of the UAS before each flight as outlined in the operating documents. I, David A. Kello , will also follow manufacturer recommendations from said operating documents. **Public Interest**Aerial photography and videography as an available service to the public allows

for a cheaper method to capturin g imagery than its alternative ( Its alternative being aircraft and helicopters). They are expensive, create lots of noise, and are much more threatening due to size and combustibl e fuel. I, David A. Kello , would gladly offer my services upon request and with proper coordination to any official search and rescue or emergency services organization to benefit the public. Also as mentioned in the Trudeau exemption, exemption No.11138 : ““Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons or more of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. T he pilot and crew will be remotely located from the aircraft. The limited weight reduces the potential for harm to persons or damage to property in the event of an incident or accident. The risk of an onboard pilot and crew during an incident or accident i s eliminated with the use of a [sUAS] for the proposed operation.” **Summary** I, David A. Kello , am seeking exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 9 1.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b) With the exemptions of the mentioned rules I, David A. Kello , will be seeking to make my drone photography/videography services available to the public. Alternatively the public had seeked to use helicopters and aircraft to achieve what I can offer in a safer, more cost efficient manner. By not using combustible fuel, flyin g at safe heights and strictly following the usage recommendations from DJI. These include but are not limited to:

 ● Flying the following UAS Safely

o DJI Inspire 1

o DJI Phantom 2

o DJI Phantom 3

o Aerosky C17

o Walkera TALI H500

 ● Flying below 400 feet ● Proper visual inspection of UAS before flights ● Keeping mentioned UAS in visual sight at all times when in operation

 ● Using an observer to assist if needed

 ● Remain well clear of and do not interfere with manned aircraft operatio ns, and avoid other aircraft and obstacles at all times

 ● Not intentionally fly over unprotected persons or moving vehicles

 ● Contact the airport or control tower before flying within 5 miles of an airport

 ● Not flying in adverse weather conditions s uch as high winds or reduced visibility

 ● Not flying under the influence of alcohol or drugs

 ● Ensure the operating environment is safe

 ● Not flying over sensitive infrastructure or property such as power stations, water treatment facilities, correctional facilities, etc.

 ● Check and follow all local laws and ordinances before flying over private property

 ● Do not conduct surveillance or photograph persons in areas where there is an expectation of privacy without the individual's permission.