Hi Sky Drones

Greg Iwinski

2008 south shore dr

Moline,Illinois

612654

309

- 269

- 7871

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

**Re:** Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113 (a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

To whom it may concern,
Greg Iwinskis drone Service writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that Greg Iwinskis drone Service, an owner and operator of small unmanned aircraft 1, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that Greg Iwinskis Drone Service, may operate a small light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein, Greg Iwinskis drone Service is experienced in testing and flyingquad copter style drones for recreational purposes. Greg Iwinskis Drone

Service has added a hobby grade quad

- copter UAS to their inventory equipped with an external gimbal mounted camera extremely high quality and a removable 8GB micro SD card. It shoots full HD video at 1080p/30fps and 720p/60fps with intent for aerial videography/ cinematography to enhance academic community awareness for those individuals and companies unfamiliar with the geographical layout of the northwest Illinois area, and augment real estate listing videos; following exemption and approval by the FAA. Thereby enhancing their academic research experience for greater northwest illinois area.
I have flown small RC electric quad copters for 2 years and make and service/repair them as well for 2 years without incident. Committed to safety with each flight. Greg iwinskis Drone Service exemption request would permit operation of light weight (less than 5lbs), unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly c ontrolled and limited airspace.2 Predetermined in areas away from general public, airports, helipads and vehicular traffic for community videos, and within property boundaries for individual homeowner real estate listing videos/ photos. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. The Pilot of Greg iwinskis Drone Service, has personally instilled safety protocols and controls3 to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's specific to real estate video and photographyusage

as recorded flight data and other information gai ned through permitted flight operations to share with the FAA through any required FAA reports to assist with future protocol and safety regulation.

Granting Greg Iwinskis Drone Service’ request comports with the Secretary of Transportation’s (FAA Administ rator’s) responsibilities and authority to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate purposes and aerial video and photography. Further, Greg Iwinskis Drone Service will conduct operations in compliance with the protocols described herein or as otherwise e stablished by the FAA.
For the reasons stated below, Greg Iwinskis Drone Service, respectfully request the grant of an exemption allowing to operate light weight, remote controlled UAS’s for academic community awareness to benefit/stimulate attraction to t he greater northwest Illinois area and to enhance real estate listing videos for homeowners as well as others wishing to have aerial video and photography who cannot afford expensive manned aircraft for the same purpose. Both of which will promote local ec onomic growth through increased employment and increased tax base. Both with public safety in mind by keeping heavier manned aircraft containing combustible fuel that that poses potential public hazard.

1 Appendix A

- FPV

- Factpry mariner waterproof drone+ quad

- copter Operator Manual**I. Contact Information:**

Greg Iwinski, Owner Greg Iwinski Drone Service Office/Mobile: (309) 269

- 7871 Email: tigermax1@msn.com

**II**

. **The Specific Sections of Title 14 of the Code of Federal Regulations From Which Greg Iw**  **inskis Dron e Service Requests**  **Exemption are:** 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

**III. The Extent of relief Greg Iw inskis Drone Service seeks and the**  **Reason it seeks Such Relief:** Greg Iwinskis Drone Service, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent Greg Iwinskis Drone Service contemplated

com mercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. Greg Iwinskis Drone Service’s, ultra light weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. We would lik e to operate the ultra light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate related UAS aerial video and photography. The Reform Act guides the Secretary indetermining the

types of UAS's that may operate safely in our national airspace system. Considerations include:

The weight, size, speed and overa ll capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for Greg Iwinskis D rone Service.
Our UAS utilizes four (4) counter

- rotating propellers for balance, control and stability. Our UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit); including cam era with gimbal. Greg Iwinskis Drone Service considers safety as foremost with each flight. Our small unmanned aircraft is designed to hover in place via GPS and operate in less than a 36 mph wind. For safety, stability and fear of financial loss, we will not fly in winds exceeding 15 mph. Built in safety systems include a GPS mode that allows

our UAS to hover in place when radio controls are released. With three modes to choose from, we utilize the GPS HOLD mode 4 for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost UAS is designed slowly descend to point of take off. We do not operate the U AS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. We are constantly on alert for any manned aircraft (Police/Med ical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should amanned

aircraft approach my location or we suspect manned aircraft may approach

near my location. Our UAS is capable of vertical and horizontal o perations, and

are flown only within my line of sight of the operator/pilot, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between three (5) to ten (10) minutes, with an altitude under one hundre d fifty (400) feet.

Greg Iwinskis Drone Service utilizes a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is 25 minutes as tested. We do not operate my UAS at or below manufacture recommend mini mum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exe rcise to insure replacement for sufficient safe level of operation. We do not believe in taking risk that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. We have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. We also practice computerized simulated flights to maintain adequate skills and response reflex time. All for the sake of safety.

4 GPS position hold, self

-leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS.Greg Iwinskis Drone Service is extremely cautious when operating the

UAS/ultra light weight unmanned aircraft and will not “create a hazard to users of the national airspac e system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of the UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airs pace system. Eagle

- Eye Drone Service’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

**IV. Ho w G**  **reg Iw inskis Drone Service’s Request Will Benefit the**  **Public A s A**  **Whole:** A erial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videogra phy is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense. Depriving

non

- luxury homeowners and lower budget Realtors from a valuable marketing tool. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act.

Granting Greg Iwinskis Drone Services’ exemption request furthers the public interest through academic/visual awareness of the geographical benefits in andaround the

greater Grand Traverse area. Our ultra light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of

our ultra light weight UA S crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by perm itting aerial video/photo capture through the battery operated ultra light weight UAS's. Permitting Greg Iwinskis Drone Service, to immediately fly within national air space furthers economic growth. Granting our exemption request substantially furthers th e economic impact for the Grand Traverse community for companies looking to relocate or build in the area as well as individuals looking to relocate for career advancement through academic and geographical

awareness. Both of which serve as a stimulus to th e community.

**V. Reasons Why**

**Greg Iw inskis Drone Service’s Exemption Will Not**  **Ad versel**  **y Af** 

**fect Safety**

**Or Ho w Th**  **e Exemption Will Provide a Level of Safety** 

**A t Least Equal To Existing Rule:**  Greg iwinskis Drone Service’s, exemption will not adversely affect sa fety. Quite the contrary, for the reasons stated, permitting Greg Iwinskis Drone Service, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow us to contribute to the innovation and implementation of new and novel , as of yet undiscovered safety protocols for Realtors that can be embraced by the NAR5, MAR6, and TAAR7 for development in cooperation with the FAA. Inaddition,Greg Iwinskis Drone Service, submit the following representations

of enhancements to current a erial videography and photography for real estate and genereal aerial and video photography:Our UAS weighs less than 5 pounds complete with a small ultra light weight high quality HD camera; We only operate my UAS BELOW 400 feet8 (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); • Our UAS only operate for 5

- 15 minutes per flight; 5 National Association of Realtors, http://www.realtor.org/ 6 Michigan Association of Realtors, http://www.mirealtors.com/ 7 Traverse Area Association of Realtors, http://www.taars .com/ 8 FPV

- Factory quad

- copter altitude ceiling is 400 feet when flown in GPS mode ! • We land my UAS prior to manufacturer recommended minimum level of battery power; • We pilot the UAS through remote control only by line of sight; • The UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; • We actively analyze flight data and other sources of information to constantly update and enhance safety protocols; • We only operate i n reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated
areas; • We conduct extensive pre

- flight inspections and protocol, during which safety carries primary importance; • We always obtains all necessary permissions prior to operation; and, • We have procedures in place to abort flights in the event of safety breaches or potential danger.

Greg Iwinskis Drone Service’, safety protocols provide a level of safety equal to or

exce eding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are theprimary

means of aerial video and photography for community awareness and real estate. While the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered light weight UAS. First, the potential loss of life is diminished because UAS's carry no people

on board and we only operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatl y diminished. Third, the small size and extreme maneuverability of my UAS allow Greg Iwinskis Drone Service to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, the UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly, our UAS has been experimentally operated for familiarization/ competency and will continue to operate at and above current safety levels.

**VI. A Summar** **y The FAA** 

**May Publish in the Federal Register:** 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, se ts forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of Greg Iwinskis Drone Servicve’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthinesscertificate

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pie ces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Greg Iwinskis Drone Service’ curren t and projected UAS's meet or exceed each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/ flight manual delineating areas of where safety can be defined.9 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602 , 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS utilizes electronic global positioning systems with a barometric sensor. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certif ications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by the owner, Greg Iwinski.

B. 14 C.F.R. § 45.23: Mar king of The Aircraft.Applicable Codes of Federal Regulation require aircraft to be marked

according to certain specifications. Our UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, we will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.
C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. Greg Iwinskis Drone Service, can achieve an equivalent level of safety as achieved by c urrent Regulations because our UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the risk levels inherent in t he commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing Greg Iwinskis Drone Service to operate their UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C .F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UASwill never operate at an altitude greater than 400 AGL; safely below the

standard of 400 AGL . Greg Iwinskis Drone Service, will however operate the UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and spe ed of my UAS, an equivalent or higher level of safety will be achieved.
E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “h ave [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Greg Iwinskis Drone Service's, UAS. However, as a safety precaution we inspect my UAS before and after each flight.

A Summary The FAA May Publis h in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because Greg Iwinskis Drone Service’s, UAS meets an equivalent level ofsafety

pursuant to Section 333 of the Reform Act. The FAA is aut horized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness cer

tificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, mainten ance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

**In summary , Greg Iw**  **inskis Drone Service seeks an exemption from the follo** **wing Regulations:** 14 C.F.R. 21, subpart H; 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. § 91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. §91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate

my ,FPV

- FActory, small unmanned vehicle/lightweight unmanned aircraft vehicle in commu nity awareness and real estate operations, and to develop economic platforms for real estate to enhance the experience of those seeking to relocate to the northwest Illinois area. Currently, area awareness and real estate aerial videography/photography rel ies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting Greg Iwinskis Drone Service’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not cont ain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential publi c risk flying to and from established air fields. Greg Iwinskis Drone Service, have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds curre ntly accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are

no personnel on board Greg Iwinskis Drone Service’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. Greg Iwinskis Drone Service’s, operation of my UAS, weighing less than 5 pounds and traveling at lower speeds within limite d areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly Greg Iwinskis Drone Service, respectfully request that the FAA grant our exemption request and am willing to cooperate insharing information to benefit the FAA, safety of manned aircraft, and the

general public at large.

Specifics of the UAS; UAV/UAS/UA Clarification The UAV/UAS/UA which Greg Iwinskis Drone Service, Petitioner, will be operating is the FPV

- Factory waterproo f drone, referred hereafter as Mariner. The inherent safety features, sophistication, programmability, GPS navigation, return home capability, airport vicinity no

- fly feature and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this a much safer UAV for the purposes of this petition. This is a hobby grade radio controlled UAV that has the capacity for software upgrades. It is light, less than 5 pounds including battery and camera. Incorporated into the programming of the Mariner is an automatic return home feature that automatically directs the craft back to point of take off should communication with the transmitter be lost. The Mariner has a cruising speed of 25 mph, with a maximum speed of 30 mph. Maximum flight time is 25 minutes. Gross weight is 4.0 pounds.

The software for the Mariner allows the operator or PIC to set maximum altitude AGL for each flight, allowing customization of flights to no higher than 100 feet, 15 0 feet, or 250 feet AGL as an examples. The 400 foot maximum AGL can be programmed into the UAV's software pre

- flight to insure compliance with FAA standards. Adding to the safety capabilities of this UAV. This UAV is programmed to remain in position when controls are released. Maintaining altitude and GPS location.The Phantom has an altitude and radar monitoring function that allows the

operator more precise determination of height, direction of flight and distance from the operator PIC. The operator or PIC can monitor GPS lock status while UAV is in flight, with the ability to anticipate loss of GPS locking so the operator or PIC can land the UAV as a precaution. Best explanation of the Mariners sophistication and c apabilities can be observed through a series of manufacture videos explaining the Mariner through this link ( http://fpvfactory.com/buy

- commercial

- drones

- quadc opters/splash

- drone

- pro

- version.html ). The Mariner maintains all capabilities defined in the video.

The Mariner's 2.4 ghz transmitter/controller/receiver rf for managing flight with a 5.8 ghz rf transmitter/receiver for video/photography functions eliminates the rf conflict experienced with the Blade 350 QX, and is by far the safer of the two when considering public and NAS safety. Considering the programmability and safety features of this UAV (Mariner), it serves as the best option to protect the Public and NAS for the purposes of this petition. The Greg Iwinskis Drone Service Petition is for UAV operation without pilot, passengers nor property on board. Considering that the Mariner UAV is a sophisticated hobby grade quad

- copter with gros s weight less than 5 pounds. Aerial video/photography operations for this petition provide service for those businesses, transferees, retirees and others considering relocating to greater northwest Illinois area who are not familiar with geographical chara cteristic, communities, services and other benefits of the area. Aerial video/photography operations for private property owners aide with an enhanced perspective for characteristics, amenities, and benefits a private property has that cannot be displayed through ground level video/photography. Petitioner Greg Iwinskis DroneService charges no additional fees for ground level video/photography.

Therefore, there is no compensation for these services. Aerial video/photography represent a small portion of vide os and photos currently offered at ground level for the community as well as private properties marketed for sale. Aerial video/ photography is an enhancement to videos/photography already offered homeowners and the public. In most cases aerial video will represent 5

- 30 seconds of a 2

- 10 minute video.

Petitioner Greg Iwinskis Drone Service is using a UAV that has the capability for taking off and landing at a single point, identical to a helicopter . There are no runways, aided take off apparatuses, nor routes that need to be flown to areas being aerial video recorded or photographed. Allowing a reduced and more confined area of flight. Home owner written consent for aerial video/photography shall be obtained prior to flight. Signs (See Appendix E) will be posted cautioning anyone within vicinity to remain back a minimum of 200 feet. Observer(s) to assist and warn/advise the PIC will be utilized in situations where spectators may be within 500 feet of the flight

area. To alleviate additional privacy concerns, petitioner also has the ability to cover up areas in movie post

- production by shading out objects (people/buildings) in the immediate vicinity.

The single UAV utilized in this petition is a hobby grade quad

- copter that does not require an airman certificate for non

- commercial flight involving less restrictive less regulated flight. UAV flight competency can be verified/obtained through AMAstandards and procedures as well as downloading the flight data from the

on board data logger. The motors, rotors, propellers, body/frame, landing pads, etc. for the UAV utilized in this petition are not complicated. Engineering and design allows layman maintenance. Recording part replacement for this UAV may pro ve redundant due to the simplicity of the craft. While the Petitioner requests waiver or exemption for maintenance records, it would be understandable if the FAA requires such data for its rule making process. However, pre

- flight inspection for cracks, dam age or other physical conditions that could hamper safe flight is a reasonable expectation. As well as post flight inspection that may aid in identifying flight conditions that may cause stress to propellers, landing gear, etc.

Thorough inspection of UAV shall be conducted and flight response tested should a hard landing or crash occur. Insuring that the UAV can operate in a safe

manner before conducting any further video/photography. Petitioner requests waiver or exemption for m arkings due to the small size of the fuselage for the Mariner. Petitioner requests modification, waiver or exemption and clarification (within reason) concerning section 91.119 prohibition of flight in congested areas. Such restriction puts home owners in subdivisions at a disadvantage by limiting enhanced marketing of their homes; thereby discriminating against them. Vertical takeoff and landing while video recording or photographing a home can allow an enhanced perspective for view or proximity of mountai ns, golf course, manmade lake or other attractions not possible through ground level video recordingor

photography. Petitioner requests waiver for this condition to allow reasonable and responsible aerial video/photography in congested areas of subdivisio ns and neighborhoods. In cases where altitude within airports is an issue, aerial video can be achieved under 100 feet.

In compliance with Section 90.151 (a) the Mariner is a battery operated UAV/ UAS with battery level monitoring capability. Fully charge d battery flight time is rated at 25 minutes, with videos/photos taking much less time to record. Operator or PIC is warned when battery level is low. Petitioner requests waiver/exemption from Section 91.203 (a) since the Mariner is a hobby grade UAV/UAS t hat should not require an airworthiness certificate nor a registration certificate. Posting of special flight authorization would not be possible since the Mariner has no cabin and is not large enough to carry a certificate. However, a special flight authorization can be maintained by the operator to make available upon request.

FPV

- Factorys Mariner waterproof drone has no serial number

- i have marked it permanately with the serial number:IW001 1 ! Height limitati on set for maximum of 400 feet AGL 2 ! Radius distance from controller set for maximum of 1000 feet 3 ! Both to aid in VLOS 4 ! Flight testing at the R/C air park has proven that due to UAS size of the Mariner, firmware programmed for maximum 400 feet AGL and 1000 distance are limited distance for maintaining VSOL without assistance of binoculars or other assistance. Most intended operation will only requires range of 20

- 100 AGL and less than 200 feet lateral distance from PIC. Limited stated distance for V SOL will be rare if ever needed.

Airman Certification: Petitioner has taken helicopter flying leessons and has 1 hours flight timeand is aware of FAA flight

regulations. Petitioner would like to seek a reasonable exemption with restriction solely to UAS operation at AGL below 400 feet with distance of flight no greater than 1000 feet. Currently there are no provisions within the FAA for governing UAS such as the Mariner for hobby or commercial use in northernwestern Illinois With hobby style drones alone sales have been "...exponentially higher than the 7,500 in 5 years estimate that the FAA put forward a year ago..." UAS potentially being flown without guidelines by unfamiliar, untrained individuals not belonging to professional organization like the AMA, who pose a threat to NAS, the public and responsible parties like the Petitioner.

Greg Iwinski 2008 south shore dr Moline,Illinois 61265