U.S. Department of Transportation

Docket Management System 1200 New Jersey Avenue, SE Washington D.C. 20590 UP North Aeronautics, DBA Alexander Favreau, Principal 1043 Manitou Dr. APT 103 Traverse City, MI 49686 Exemption List: 14CFR 91.7(a);91.9(b)(2);91.103;91.109,91 .119(c);91.121;91.151(a)(1);91. 203(a)(b);91.405(a); 91.407(a)(1); 91.409(a)( 1) and ( 2); 91.417(a)and(b); 45.23(b); part 21; 61.113(a)(b)
To Whom it may Concern. I am writing to pursue the reform act of 2012, and the proc edures contained in 14 C.F. R 11, to reque st that Up North Aeronautics DBA be exempt from the Federal Aviation Regulations (FAR’s) listed above so that Up North Aeronautics DBA will be able to operate light unmanned aircraft systems (UAS) in airspace that i s regulated by the Federal Aviation Administration (FAA); as long as operations are conducted within and under the conditions that are outlined herein or as may be established by the FAA as required by Section 333. It is the request of the petitioner for exemptions listed above in order to safely and legally operate the DJI Phantom 3 Advanced UAS, in the National Airspace System for the operations of photography and Videography for real estate, insurance, utility and telecommunications industries. Described herein is the pursuance to enhance safety for the general public, flight crews, and labor forces as well as public awareness of UAS operations. The main purpose for exemptions listed above is to allow Up North Aeronautics DBA utilize UAS’s for inspections for residential and commercial real estate inspections, construction inspections, search and rescue if needed, and homeowner’s insurance inspections. The main purpose for the requested exemption is t o allow Up North Aeronautics DBA to utilize UAS’s to as sess and inspect residences and business in the account of insurance, weather be commercial insurance or home owner’s insurance for claim assessment, survey construction sites, bridges and other civil structures. Real estate photography and videography. Al lowance to inspect and use of photography and videography would be contingent on obtaining written consent to access these locations by the property owners and insurance companies. The si te access woul d allow Up North Aeronautics DBA to perform and conduct flight operations which include inspections at low altitude and always within Visual Line of Sight (VLOS). All inspections, photography, and videography would be conducted within 300’ feet AGL (Above Ground Level) and utilize Pilot in Command (PIC) as wel l as Visual Observer (VO). Some of the safety measures taken to assure safety for all personnel and structures I would cordon off the site to alleviate excess personnel on the site, I will do so by manor factors but primarily with signs and cones advising of the possible hazard. Up North Aeronautics DBA and its UAS’s would alleviate the exposurefor the insurance personnel on a day to day basis by eliminating any height factor of the manual

inspections. Some of the inspections that would be included for the claims process would be for gutters, siding, windows, and roof inspections. The UAS would decrease the time it would take to do the inspections, this would increase productivity and assist in making the inspections more thorough. Using the UAS would allow the insurance personnel to stay on the ground instead of climbing a ladder either to inspect the roof, siding, windows, which would minimize the risk of falling, harm, or even death associated with this type of operation. The operations listed above may require flight within 100’ feet from buildings and structures. The safety measures that have been implemented to minimize risk and exposures of damage to any structure or harm to any persons on the site would include

 Written permission from the property an d building owners describing potential hazards and outlining the flight operations.
 General Liability coverage to cover any damages
 All flight operations to follow operation manual guidelines and procedures included herein Safety is of utmost importance to Up North Aeronautics DBA, we hope to perform safety by incorporating several flight parameters, conditions, guidelines and limitations to adhere preflight, in flight, and post flight operations which all are outlined in the UAS user/operator manual.

 The U AS will not exceed a ground speed of 30 Knots
 All operations will remain below 300’ Feet AGL  All Operations will remain in VLOS
 The UAS will weigh less than 55 pounds
 A VO will be utilized at all times and always will have verbal communication with PIC
 The Operator must follow the procedures outlined in its operator’s manuals which includes Protocols and Procedures, DJI user’s manual and operator’s manual, which are included
 All PIC’s must carry at least a private pilot license, experimental license, spo rt pilot license, or Glider license.
 All PI C’s must carry at least a Third

- class medical
 All PIC’s must meet flight review requirements specified in 14 CFR 61.56
 Prior to each flight the PIC must inspect the UAS to ensure flight safety.
 Any UAS that has u ndergone alterations or maintenance must undergo a functional flight test in accordance with the operator’s manual
 UAS aircraft component, maintenance, overhaul, replacement, inspection, and life limitations address by manufacturer must be followed
 Each PI C must undergo specific training for the type (multi

- rotor), make and model aircraft and log hours appropriately.
 PIC must maintain proficiency and currency (every 90 days) with UAS.
 Both PIC and VO must successfully complete a qualification process that is outlined in operators manual and must be documented
 The UAS will not be operated directly over any person, except authorized flight personnel only with their consent. The PIC and VO will ensure that no unauthorized persons allowed within a safe distanc e deemed by physical terrain constraints, or 3 00’ feet.
 Lost communication or GPS signal while in flight, the UAS must return to pre

determined location and be recovered or land safely in accordance with the operator’s manual
 The UAS must abort any flight in the event of unpredicted obstacles or emergencies in accordance with operator’s manual
 All operators will comply with all manufacturers safety information
 The UAS will not operate in Class B, C, or D, airspace
 The UAS will not be operated by PIC from m oving device or vehicle
 At all times the UAS must remain clear and yield to all manned operations and activities at that time.
 All operations will be conducted under Visual Flight Rules (VFR)
 There will be no night operations as defined in 14 CFR 91.151
 Th e UAS will not be operated less than 500’ feet below or 2000’ feet horizontally from any clouds
 The UAS will not be operated with less than 3 statute miles of visibility
 The documentation required under 14 CFR 91.9 and 91.203 will be available to PIC at all times at the ground station
 The radio frequency spectrum used for operations and control of UAS will comply with the Federal Communications Commission (FCC)
 Accidents will be reported to the National Transportation Safety Board (NTSB)
 Any incident, a ccident, or flight operation that extends past the lateral or vertical boundaries of the operational area defined by applicable COA will be reported to the FAA’s UAS Integration Office (AFS

-80)
 The UAS operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver/ Authorization (COA) prior to conducting operations.
 Up North Aeronautics DBA will operate the local Flight Standards District Office (FSDO) in writing 3 days prior to any operation to define activities and flight operations t hat are going to take place. **Exemption request:** 14 CFR 51, Subpart H: Airworthiness Certificates;
 The petitioner requests relief from 14 CFR 51 Subpart H taking into account the size, weight, maneuverability and requirements that are outlined towards ai rports and dense populations which the (business) must meet and exceed the operation limits outlined. 14 CFR 61.113(a)(b): Private Pilot Privileges and Limitations PIC;
 Private Pilots are limited to Non

- Commercial operations.
 The UAS’s used in this operation do not carry any pilots or passengers.
 Every PIC will need to must attend the pilot vetting and training to further flight skills operating UAS to ensure safety while flying UAS. Only then will the PIC’s that are operating the UAS’s will have the skills that a private pilot license does not ensure for flight of any UAS. Obtaining the necessary training that (business) requires will ensure and exceed current safety

levels in relation to 14 CFR 61.113(a)(b). 14 CFR 91.103: Pre
-flight:
 For preflight action every PIC must abide by operating documents which include weather, flight battery requirements, landing and take

-off distances and aircraft performance data before initiating each flight, there will be no approved Aircraft Flight Manuals on board t he aircraft but all operating documents will be available to PIC to directly follow at the ground station. 14 CFR 91.109: Flight Instruction;

 There will not be flight instruction available , no dual controls are available on the UAS 14 CFR 91.119 (c) : M inimum Safe Altitude ;  No person may operate an aircraft o Over other than congested areas, an altitude of 500 Feet above the surface except over open water or sparsely populated areas. o Sparsely populated areas and open water the aircraft may not be operated closer than 500 Feet to any person, vessel, vehicle or structure.
 For the type of operations (photography and videography), the petitioner will operate between 0’ feet to 300’ feet AGL, the majority of time will be within 200’ feet AGL.
 The DJI Phantom 3 Advanced is not able to exceed speeds over 30 knots and is remarkably lightweight.
 UAS is equipped with GPS guided auto pilot which enables a return to home function in the event of loss of control by PIC.
 Post impact fire is reduced with sealed batteries.
 The primary uses for this UAS will be directly correlated with home inspection, videography, and photography of residence and business structures, in these cases Up North Aeronautics DBA would need to be exempt from 14 CFR 91.119(c) to be able to fly with in 500’ feet to get best angle of capture.
 In these operations conducted, PIC would need the expressed permission of the property owner and every safety precaution will be made to keep persons outside of a safe, reasonable, and clear area of operations, fo r more information on precautionary events please see the Protocols and Procedures section. 91.121: Altimeter setting;
 The Petitioner requests relief from 14 CFR 91.121, the DJI Phantom 3 Advanced is equipped with GPS derived altitude capabilities. 14 C FR 91.151(a)(1): Fuel Requirements;
 No person may begin a flight in an airplane under VFR conditions unless PIC takes into consideration the wind and forecast weather conditions unless there is enough fuel to fly to the first point of intended landing and, assuming normal cruise speeds. During the day to fly for at least 30 minutes. The Petitioner requests relief from 14 CFR 91.151(a) taking in consideration that the UAS is

equipped with a battery system that has a built in power percentage indicator system
.  The max flight time for the DJI Phantom 3 advanced has a total flight time of 23 minutes respectively depending on camera usage, flight conditions and other variables. The established amount of time on a fully charged b attery will be no longer than 16 minutes, this will give the 25 percent battery/ fuel left over wit h an excess of about 2 minutes for safety and considering flight conditions and other variables that can affect flight time. 14 CFR 91.405 (a): Maintenance Required ;  The Petitioner requests relief from 14 CFR 91.151(a)(1), please see the Protocols and Procedures section on Maintenance and Maintenance Required. 14 CFR 91.407 (a)( 1): Operation after Maintenance, Preventive Maintenance, rebuilding, or alteration;
 The Petitioner requests reli ef from 14 CFR 91.407(a)(1) please see the Protocols and Procedures section on Maintenance, Return to service after Maintenance, and Maintenance records. 14 CFR 91.409 (a)(1)(2) : Inspections;  The Petitioner requests relief from 14 CFR 91.409 (a)(1)(2), please see the Protocols and Procedures section on Inspections. 14 CFR 91.417 (a)(b) : Maintenance Records;
 The Petitioner requests relief from 14 CFR 91.417 (a)(b) please see the Protocols and Procedures section on Maintenance Records.
14 CFR 91.7(A): Airworthiness Certificate;
 Prohibits the operation of an aircraft without an airworthiness certificate. Request for exemption by petitioner based on previous exemption no. 13660. The FAA has rul ed that this make and model of UAS does not require an airworthiness certificate. 14 CFR 91.9(B)(2): Aircraft Flight Manual ;  Requires an aircraft flight manual in the aircraft at all times. Being an unmanned system no pilots or passengers are on board and taking into consideration the size and weight of UAS. 14 CFR 45.23(b): Aircraft Markings

 The petitioner requests relief from 14 CFR 45.23(b), stating that the markings on the aircraft must include the Roman Capital Letter “N” and must be displayed at ea ch entrance to the cockpit or pilot station in letters larger than 6 inches tall and no less than 2 inches tall. Being that the UAS is an unmanned system, the aircraft does not have a cockpit or pilot stations. Being a small lightweight aircraft the requirements for 2 Inch lettering may be difficult. If requi red for Up North Aeronautics DBA to mark its aircraft on its fuselage as stated in 14 CFR 45.29 (f) , markings will be put on the aircraft as large as possible so that the pilot, technician, VO, and othe rs that are working with or near the UAS will be able to see the markings.**Procedures and Protocols for UAS operations :** 

**The Unmanned Aircraft system** The Petitioner will be operating the DJI Phantom 3 Advanced Quad

- Rotor UAS System, this will be the only system to be operated by the petitioner. This system is ultra

- lightweight weighing at 1,280 G. Many features have been implemented on/into this UAS to ensure safety. Some of the safety features that have been implemented into this system are GPS return to home feature which will land the aircraft to a predetermined safe area. The GPS also implemented that the PIC can take control while on return to home feature if necessary. No fly areas, the GPS will atomically know when it is about to enter, or takeoff i n a no fly zone and will not allow the PIC to proceed with either, to ensure safety. Please see the attached hyperlinks that have been attached that will include operating and user documents for this system as additional information for t his petition. **Area Security/Safety**  1. The PIC of the UAS will ensure that the area of operations will be cleared of all persons that are deemed to be not essential to the flight. All persons that are considered to be not essential to the flight will be cleared of the area of o perations and give a safety buffer of no less than 200’ feet or an amount practical during any time of operations. For the safety of the public cones and signs will be incorporated to assist in keeping the area of operations clear throughout the duration of the flight. **Pre -**  **Flight Inspections:** 1. All PICs of the UAS must have available the pre

-flight inspection for UAS given by the DJI Phantom 3 Advanced manual s available, and must follow the instructions given said manual. The PIC will certify that the preflight inspection has been accomplished in full and must provide date time and signature showing it was complete. The preflight inspection must include all of the following for the UAS; a. Aircraft: b. Transmitter: c. Batteries: d. Motors: e. Landin g Gear: f. Camera: g. Gimbal Mount: 2. As a part of the preflight inspection the PIC must assure that all listed below must be attained prior to flight. a. Weather Conditions: b. Area Security: c. Any other information that is deemed essential for safe flight: **UAS Airworthiness** 1. The PIC must ensure the airworthiness of the UAS prior to each flight. Airworthiness must be ensured by the following a. DJI Phantom 3 Advanced operating documentsb. Any applicab le Federal Aviation Regulations c. Requirements defined by the Administrator 2. The PIC must document a. Preflight inspection with signature and date b. Aircraft flight time to date c. Any discrepancies noted (shall be addressed before any operations) d. Certificate number **Operation Limitations:**  1. The UAS must be operated in day time only defined in 14 CFR 2. Night operations for UAS are prohibited 3. The PIC must obtain at least a Private Pilot certificate in most appropriate Class and Category 4. The PIC must obtain and carry at lea st a 3 rd class medical certificate 5. PIC must meet the flight review requirements listed in 14 CFR 61.56 6. PIC is required to operate the UAS in accordance with 14 CFR 91.119 7. UAS will not be operated within 5 Nautical Miles of a controlled airport denoted on a current FAA chart. 8. No operations are permitted in the surface of a class B, C, and D airspace or restricted area. 9. PIC needs to attain the appropriate Certificate of Authority issued by the administrator. 10. The UAS will be limited to 75% of battery power or 16 minutes 11. The PIC will need to acquire permission from the property owner to fly within 150’ feet 12. UAS will not be operated from a moving platform or vehicle of any type. 13. A Visual Observer (VO) must be present and must maintain VLOS at all times 14. VLOS mu st be maintained at all times during UAS operations 15. The only UAS to be utilized will be the DJI Phantom 3 Advanced 16. The restriction for altitude will be implemented stating all operations must be done below 300’ feet AGL 17. The restriction for horizontal dist ance away from PIC must be within 1,000’ feet 18. The UAS must not exceed 30 Knots (35 MPH ) 19. PIC must accumulate and log a minimum of 25 hours of total flight time as a UAS rotorcraft pilot 20. For PIC currency before any operations the PIC must accrue a total of 5 hours as a UAS pilot in the same Make/Model listed, and must log a minimum of 3 takeoffs and landings within 90 days prior. 21. The Maintenance of the UAS must follow the DJI Phantom 3 Advanced aircraft and component, maintenance, overhaul, replacement, inspe ction and life limit requirements. 22. In accordance with the operating documents all Maintenance, Inspections, and Re cord keeping must be up to date and must include total flight hours, description of work performed, date of operations and signature of opera tor must be included. 23. After any maintenance or alterations that may affect the UAS, an operational flight test must be completed and documented. 24. The UAS and ground control stations must be inspected and deemed airworthy conditions prior to any operations ; if the UAS or ground station is deemed un

- airworthy, all flight operations will be suspended until necessary maintenance has been performed and the UAS and Ground Station has been deemed airworthy once more.25. All operation documentation will be accessibl e to the PIC at all times and must be able to be

presented to the Administrator upon request. 26. The UAS must comply with all of the safety bulletins from the manufacturer 27. If the return to home function and or autopilot are suspected of malfunctioning no ope rations are permitted and any ongoing operations must cease. 28. The PIC and VO must observe the area of sky surrounding the area of operations, if any manned aircraft is being operated in close proximity of the operations, the UAS must give right of way to the manned aircraft and operations must cease to continue until the manned aircraft is clear of the area. **Pilot in Command Requirements** 1. The PIC must hold at least a Private Pilot Certificate and a current Third Class Medical whenever conducting any operati ons. 2. The PIC must accumulate a total of 25 hours 0f rotorcraft UAV flight time 3. The PIC must have at least 10 hours of flight time with the make and model of UAV 4. A Preflight inspection must be performed and documented before each flight is conducted 5. The P IC must have a VO present to operate 6. The PIC must maintain and record flight information to establish currency and the operator must meet all requirements in this section 7. The PIC must observe and obey all Federal Aviation Regulations at all times exception s include exemptions listed
**Responsibilities and Requirements for Visual Observers** 1. During any UAS operations a Visual Observer must be present 2. Verbal communication between the Visual Observer and the PIC must be kept at all times 3. The Visual Observer must keep Visual Line of Sigh t with the UAS at all times 4. If Visual Line of Sight is lost with the Visual Observer, the PIC will be notified verbally and operations will cease 5. The Visual Observer will assist the PIC with operations area security to ensure that all persons that are not essential remain clear of area 6. If there is a breach of unauthorized personnel, the Visual Observer will notify the PIC and all operations will cease until area is clear 7. The Visual Observer will assist the PIC in observing the area for any manned aircraft traffic, if there is any manned aircraft traffic in the proximity the Visual Observer will notify the PIC and all operations will cease until the area is clear. **Maintenance and Records:** 1. Each UAS shall have its own and separate main tenance log book 2. The PIC shall maintain all aircraft maintenance in the specified log book specific to UAV 3. Performing repairs, inspections, overhauls and replacement of life limited components a. Only the DJI Phantom 3 Advanced documents, handbooks, user manuals, supplements, etc. shall be the only approved documents for any of the maintenance listed above4. Maintenance records must be kept with the UAS at all times and must be accessible to any

authorized agency or the administrator upon request. 5. All requi red maintenance inspections, alterations or repairs must be completed by an approved person. Once completed the approved person must make an entry in the log book that includes a. Date b. Aircraft serial or operating number c. Description of the discrepancy, inspection, alteration, or repair d. The reference material used as guidance for repair e. Statement approving the aircraft to return to service f. Signature of person who completed work
**Reporting of incidents or Accidents :**  1. The applicable COA operating the UAS must re port any incident or accident within 24 hours to a. FAA UAS Integration Office (AFS

-80) Accidents: National Transportation Safety Board ( WWW.NTSB.gov ) **The Public Interest:** The request for this exemption is in the Public Int erest as is a safe vehicle engineered to make sure that it is lightweight, fire resistant, and environmentally friendly resource that could make the labor force and environment a safer place. This system is virtually quiet from afar compared to its manned aircraft counter parts, it will not disrupt personnel with the noise that a manned aircraft brings. These aircraft can provide numerous amounts of services without risk of loss of life or harm. It has become clear that many areas want these systems to be i ntegrated into the NAS, including the Congress of the United States of America, the consumers and many business’. Not only are these systems very efficient but the growing rate and wide acceptance of these systems will have a big toll in the economy. By granting this petition it will help the Administrative process’ to help create regulations to further safety in the future and guidance for the growing community that is UAS.
For any questions or concerns please send to the email address listed below Sincerely, Alex Favreau 1043 Manitou Dr. APT 103 Traverse City, MI 49686 (616)438

-8214 Favreaa4228@gmail.com