### S **ummary of Exemption request:**

Pursuant to section 333 of the FAA Modernization and Reform Act of 2012, and the Federal Aviation Administration’s general exemption authority under Title 49, United States Code, Section 44701(f), Fearl é Aerography hereby petitions for exemptions from the following Federal Aviation Regulations specified in Title 14 of the Code of Federal Regulations.

If the se proposals are granted, Fearlé Aerography will be allowed to operate their Unmanned Aircraft Systems (UAS) a nd will allow the following commercial applications:

 Commercial Real Estate Videography

 Aerial Mapping

 Commercial Artistic Videography

Fearlé Aerography petitions for a Grant of Exemption so that the company can conduct aerial videography and cinematograp hy to enhance aerial mapping and augment real estate listing videos. We request exemption from:

o 14 CFR Part 21, Subpart H
o 14 CFR 45.23
o 14 CFR 61.113(a)(b)
o 14 CFR 91.7(a)
o 14 CFR 91.109(a)
o 14 CFR 91.119(c)
o 14 CFR 91.9(b)(2)
o 14 CFR 91.121
o 14 CFR 91.151(a)(1)
o 14 CFR 91. 203(a)(b)
o 14 CFR 91.319(a)(1)
o 14 CFR 91.405(a)
o 14 CFR 91.407(a)(1)
o 14 CFR 91.409(a)(1)(2)
o 14 CFR 91.417 (a)(b)**Information of Applicant:**

Fearlé Aerography Austin Doughty 940 W Round Grove rd. Unit #2235 Lewisville, TX 75067 817

-559

-9475 ajdoughty90@gmail.com **Qualifications of Applicant** :
 Airline Transport Pilot #3620756

 CFI, CFII, MEI

 10 years experience of building and operating numerous R/C aircraft.

 2 years experience of operating drone type aircraft for hobby use.



### Aircraft Overview: Fearlé Aerography will operate both the Phantom 3 and Inspire 1 UAVs. These aircraft are based on a quad rotor design. A lithium polymer battery powers the counter rotating electric motors. These drones provide excellent predictability, stability, and control. These aircraft have an operational weight of less than 10lbs. The aircraft flight endurance i s 20 minutes on each battery with a maximum airspeed of 20 knots for the phantom 3 and 34 knots for the Inspire 1. These drone Aircraft have GPS utilization that allows for accurate physical positioning. These aircraft have iPad tablets at the ground control station that allow precise airspace positioning. If signal is lost during operations, the drone is capable of initiating an automatic return home sequence. Also if the battery level drop s below 20%, the aircraft will execute a return home to base. The a ircraft has forward and rear position lighting to signal the direction of flight.

### Safety **Procedures :** 

Safety wi ll be our primary goal at Fearlé Aerography . Along with compliance with all FAA mandates and regulations for unmanned aircraft, we have adopted our own safety procedures. These procedures will include the following safety protocols: 1. All PIC’s will have FAA Commercial Licenses 2. All PIC’s will be th oroughly trained with FAA Drone regulations 3. All PIC’s will have current FAA class 3 medicals 4. All PIC’s will go through the Fearlé Aerography ground training program that will teach the operators the specific UAV they will be operating. Additionally weather requirements and normal and emergency procedures for the UAV will be covered. 5. We will require all PIC’s to maintain records with regards to currency and flight hours in a pilot logbook. 6. We will have separate maintenance logbooks for each drone which will include preventative and corrective maintenance actions performed on the drone. 7. We will require that each PIC will acquire 25 hours UAV t ime with at least 10 hours in make and model prior to commencing commercial operations. 8. We will require all PIC’s to have 3 take offs and landings prior to commencing any commercial operations. 9. All PIC’s will be required to check all notams in the operati ng area prior to any commercial flight. 10. Fea rlé Aerography will advise local residents or businesses in the immediate area of flight that drone operations will be taking place. In addition Fearlé Aerography will place signage indicating that UAV flight will be operating in the immediate area. 11. All PIC’s will maintain visual line of sight with the drone at all times. 12. In addition to the PIC, we will have a trained safety observer that will be proficient in airspace knowledge, emergency procedures, ground opera tions of the UAV, and obstacle awareness. 13. Prior to any commercial flight, we will develop a flight plan that will be strictly adhered to. We will insure all safety precautions will be taken for each flight.

### Regulations:

14 CFR Part 12, Subpart H : Procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approvals. Given the size and weight of the Phantom 3 aircraft and the limited operating area associated with its utilization , it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels.

14 CFR 45.23(a): Display of Marks; General Because of the size of the aircraft, we propose that 1 inch markings denoting the tail number on its fuselage. This is so the pilot, observer, and the ground crew personnel will see the aircraft marking to denote the serial number.

14 CFR 61.113(a) and (b): Private pilot privileges and limitations; Pilot in Command Because there we will not be flying any passengers or property for hire, we feel that an operator with a private pilot will be sufficient to carry out the responsibilities of the PIC.

14 CFR 91.7(a): Civil aircraft airworthiness This regulation requires that no person may operate an aircraft unless it is in airworthy conditions. We request an exemption to this regulation because the Phantom 3 has no airworthy condition set forth by the FAA. We will also ensure that the aircraft is in airworthy conditions at all times and will terminate a flight in the event we find it is not airworthy.14 CFR 91.119(c): Minimum safe altitudes

This regulations states that no aircraft can be operated over congested areas of a city, town, settlement, or over any open air a ssembly of persons, an altitude of 1,00 feet above the highest obstacle within a horizontal radius of 2,00 feet of the aircraft. Subpart (C) focuses on restrictions of operating at an altitude of 500 feet to any person, vessel, vehicle, or structure. We w ill not operate the Phantom 3 near any powerlines/power structures, or any congested areas. Because of the size and weight of the Phantom 3, we feel that there is very little risk flying less than 500 feet around areas other than congested areas. We will e nsure that will gain permission to operate within 500 feet of any private property. The owners of that property will always be informed of any unmanned flight operations. We also feel that operating below 400 feet will be the safest cushion for work. We wi ll practice constant airspace awareness to allow separation of UAS operations and property.

14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft This regulation requires that for any person to operate a US registered civil aircraft, there must be a current approved airplane or rotorcraft manual readily available. There is no room for any manual to be place on the UAS itself. However, a flight manual and any documentation will be made available at the ground station of the flight operation. Alth ough there is no FAA approved flight manual for the Phantom 3, we will provide the manufacturer user manual and check list for safe operation.

14 CFR 91.109(a): Flight Instruction This regulation prescribes that no person may operate a civil aircraft tha t is being used for flight instruction unless that aircraft has fully functioning dual flightcontrols. The Phantom 3 has no dual flight controls and we wish to be exempt

from this rule.

14 CFR 91. 203(a)(b): Carrying Civil Aircraft Certification and Regi stration This regulation states that no person may operate an aircraft unless it has an appropriate and current airworthiness certificate. This certificate must be displayed in at the cabin or cockpit entrance so that it is legible to passengers or
crew. The Phantom 3 has no airworthiness certificate and no place on board to carry certification or registration documents to display them. We believe that this requirement would not be appropriate. However, we will have all documents and certificates applicab le at the ground station of operations.

14 CFR 91.121: Altimeter settings This regulation requires aircraft operators to maintain cruising altitude or flight level by reference to an altimeter. The Phantom 3 uses GPS and internal barometric altimeters to determine altitude. This method will be used for maintaining level flight. We believe this regulation is not applicable.

14 CFR 91.151(a)(1): Fuel requirements for flight in VFR conditions The Phantom 3 uses battery for its source of power. Therefore, we believe exemption should be granted as the regulation is not applicable. However, we will ensure that at 30% battery power, the aircraft will return to its point of landing.

14 CFR 91. 405(a ): Aircraft Inspection This requirement states that an aircraft operator or owner shall have that aircraft inspected as prescribed in subp art E of the same part and shall have discrepancies repaired as prescribed in part 43 of the chapter 4.There is no approved maintenance program for the Phantom 3 however, we will

ensure that it goes through a rigorous annual inspection.

14 CFR 91. 407(a)(1): Approved maintenance This section states that no person may operate an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service by an authorized person. If there is any maintenance that includes a major change of engines or propellers, the aircraft will be tested by the PIC in a remote unpopulated location to ensure the aircraft is operating safely.

14 CFR 91.409(a)(2): Routine Maintenance This section states that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of airworthiness certificate. After any major maintenance, the aircraft will undergo a test flight in a remote unpopulated area to ensure the aircraft is operating safely.

14 CFR 91.417(a)(b): Aircraft logbook This section prescribes that each owner or operator of an aircraft shall keep a record of the aircraft. This record will include the time log and maintenance records over the lifetime of the aircraft. We will maintain an aircraft logbook that will include flight time and any maintenance preformed on the UAV. We will be diligent to ensure the accurate status upkeep of the maintenance record to include the battery mainten ance log, software that is current prior to aircraft operation, and ensuring the aircraft is safe for flight.

### Summary:

Fearlé Aerography believes that approval from the FAA will allow us to provide safe operations of our unmanned drones. With being granted this exemption, we will greatly enhance the ability to showcase commercial and residential properties. Until recently, potential buyers of these properties can now see these properties without physically having to be at the location. We are able to map large properties for potential customers, eliminating travel to and from the perspective property. Through the FAA exemption process, operators will be required to prove standard operating practices and procedures, thereby eliminating non licensed hobbyist in the NAS. With these strict guidelines in place, we firmly believe this new industry will become a viable commercial industry.