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Michael Scott Reeves
8134 North 70 th East Ave Owasso, OK 74055

October 30 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE Washington DC 20590

Reference: 

### Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations from certain parts of the FARs.

Dear Sir or Madam:

Michael Scott Reeves (hereinafter Mr. Reeves) seeks exemption from the req uirements listed in this
document to operate a small Unmanned Aircraft System (sUAS) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Mr. Reeves to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video graphy and pho tography for real estate, infrastructure and construction inspections, pub lic events, sporting events, mapping, surveying

, marketing and training

.

I. NAME AND ADDRESS OF THE PETITIONER The name and address of the Petitioner and point of contact is:

Michael Scott Reeves
8134 North 70 th East Ave Owasso, OK 74055

918

- 630

- 7611 MScottReeves@me.com

II. REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

Mr. Reeves requests exemption from the following applicable regulations, pursuant to the
Administrator’ s authority to grant exemptions contained in 49 U.S.C. §106(f), 40113, and

44701:

 14 CFR 61.23 (a) and (c)

 14 CFR 61.101 (e)(4) and (5)

 14 CFR 61.113 (a)

 14 CFR 61.315 (a)

 14 CFR 91.7 (a)

 14 CFR 91.119 (c)

 14 CFR 91.121Page | 2  14 CFR 91.151 (a) (1)

 14 CFR 91.405 (a)

 14 CFR 91.407 (a)(1)

 14 CFR 91.409 (a)(1) and (2)

 91.417 (a) and (b)

III. PROPOSED UAS

Mr. Reeves seeks the above exemptions to operate DJI Phantom 3 and DJI Inspire 1 sUAS’s for compensat ion or hire within the NAS. These sUAS’s are a vertical takeoff and landing (VT OL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electroni c tablet or smartphone systems. The DJI Phantom 3 has a maximum gross wei ght of approximately 2 pounds 13 ounces, while having a length of 16 inches

, width of 16 inches, height of 8 inches, and a m aximum speed of approxima tely 30 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 k nots. The DJI Phantom 3 and DJI Inspire 1 s UA ’ s are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The sUAS’s that will be operated by Mr. Reeves will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Mr. Reeves operati on of sUAS’s meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpa rt H.

Mr. Reeves requests relief from Sections 91.405(a), 91.407(a) (1), 91.409(a) (1) & (a) (2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to
aircraft with an airworthiness certificate. Mr. Reeves submi ts that the requested relief is proper since an equivalent level of safety will be ensured. Mr. Reeves will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the sUAS’s using the methods, techniques, and practices prescribed in the operating
documents.

Mr. Reeves seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because
the sUAS’s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As s uch, Mr. Reeves will ensure tha t the sUAS’s are in condition for safe operation, prior to every flight, by determining that the sUAS ’s are in compliance with the operating documents and that the aircraft is in a condition for safe flight including a
thorou gh preflight inspection.

Mr. Reeves also seeks an exemption from the requirements of Section 91.121, entitl ed Altimeter Settings, as the sUAS’s will not have a typical barometric altimeter onboard.Page | 3 However, altitude information will be provided to the PIC via GPS equipment and radio communications telemetry data link, which downlinks from the sUAS to the GCS for active monitoring of the flight path. This altitude information, combined with operations in visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section

91.121.

Additionally, Mr. Reeves seeks an exemption from the requirements of Section 91.151(a ) (1) entitled Fuel requirements for flight in VFR conditions. Mr. Reeves submits that safety will not be affected by operati on of the sUAS’s during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a to tal duration of approximately 20

- 30 minutes . Mr. Reeves will ensure missions are conducted with sufficient reserve to operate for at least 5 minutes after the intended mission is complete.

IV. UAS PILOT IN COMMAND

M r. Reeves petitions for r elief from certain requirements of Section 61.23(a), 61.101 (e) (4&5), 61.113(a)

, and 61.315(a) d ealing with C ertification : Pilots, Flight Instructors, and
Ground Instructo rs. In previous petitions for exemption, the FAA has held that a PIC of a sUAS holding at least a Sport Pilot certificate and a U.S. Driver ’ s License, or greater medical certification, would not adversely affect safe operations within the NAS or present a hazard
to pe ople or structures on the ground. For this reason relief is requested.

V. PROPOSED OPERATION(S) OF THE UAS

Mr. Reeves proposes the following guidel ines and limitations to ensure safety in the NAS:

1. The DJI Phantom 3 and DJI Inspire 1 will be operated at less than 50 knots groundspeed.

2. The PIC shall operate the DJI Phantom 3 and DJI Inspire 1 at least 500 feet from nonparticipants

. 3. Flights will be operated within unaided visual line of sight of an operator and observer.

4. All flights will be conducted in daylight, Visual Flight Rules (VFR) conditions.

5. Flights will be operated at an altitude of no more than 400 feet AGL.

6. Maximum total flight time for each operational flight will be 30 minutes.

7. Flights will be termina ted at 20% battery power remaining should that occur prior to 30

minutes.

8. Minimum crew for each operation will consist of the sUAS Operator, the Visual Observer and may include a securi ty coordinator

. 9. A briefing will be conduc ted in regard to the planned sUAS operation prior to each flight.
All personnel who will be participating in that flight shall be present for the preflight briefing.

10. When necessary, and at least 72 hours prior to flight, the o perator will file FAA Form

7711

- 1, or its equivalent, with the appropriate Flight Standards District Office.

11. Observer and Operator will at all times be able to communicat e by voice with each
other.

12. When necessary, permission from relevant prope rty owners will be obtained.Page | 4 13. If the sUAS suffers a ‘lost link’, the DJI Phantom 3 and DJI Inspire 1 will perform the predetermined flight maneuver to land as soon as practical as outlined in the preflight briefing.

14. The operator will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

15. All accidents and incidents shall be recorded in the aircraft log and reported in
accordance with FAA directives.

VI. PUBLIC INTEREST Granting the present Petition will further the public interest by allowing Mr. Reeves to safely, efficiently, and economically perform aerial videography and photography for real estate, infrastructure and construction inspections, public events, sporting events, mapping, surveying, marketing and training

. The DJI Phantom 3 and DJI Inspire 1 are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. Additionally, conducting these operations with the DJI Phantom 3 and DJI Inspire 1, instead of manned aircraft, will greatly 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 sUAS ’s produce no air pollution, and is the most viable environmentally conscious alternative to the aircraft that are typically utilized for aerial video and photography. By using the sUAS ’s to perform aerial services, 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 sUAS ’s have le ss physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations.

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to working with your office. Please contact me at any time if you require
additional information or clarification.

Sincerely,

Michael Scott Reeves

918-630-7611 MScottReeves@me.com