To:

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590
From: Aerial Imagery Services (AIS) Attn: Rylan Miller 30 Cypress Creek Dr. Murrells Inlet, S.C. 29576 (224) 730

- 1839 Rylanmiller777@gmail.com 

### Re : Request for Exemption under section 333 of the FAA Reform Act

Regarding the Unmanned Aircraft System The UAS currentl y being used is DJIS1000+, SJIS1000, DJIS900, DJ I S800, DJI Phantom 3. All UAS being utilized weigh less than 55 Lbs. Since the UAS weighs less than 55lbs and carries no fuel the damages that can be caused due to unforeseen circumstances are mitigated. In comparison to manned aviation where aircraft can weigh in excess of 1,000 lbs and carry highl y combustible fuel such as 100LL the unmanned aircraft systems being proposed b y AI S are a fraction of the danger and provide the same results. The aircraft flown b y AIS will undergo a preflight inspection prior to ea ch flight in accordance with the operator ’ s manual set forth by the manufacturer. In addition, AI S will comply

with any other operational guidelines required b y the FAA.
AI S will implement a strict maintenance program that will ensure safe aircraft oper ations. AI S will do this by

incorporating the aircraft’s operating manual as well as any guidance and direction given b y the FAA. Operating frequencies are 2.40

– 2.483 ghz for the aircraft’s remote control
Regarding the Unmanned Aircraft PIC Aircraft PI C: All UAS PI C’s employed by AI S will be licensed pilots with a current FAA medical . In addition, PI C’s will undergo training on the UAS platform they are operating. AI S will implement a written examination to test our pilot’s fundamental knowle dge of the platform they

are fl yi ng.

### Visual Observer:

Visual Observers will be trained on the fundamentals of flight and public safety . AIS will train visual observers how to operate the company ’s Remotely Piloted Aircrafts (RPA) so that they

will have a fundamental knowledge of the aircraft and its flight c haracteristics. Furthermore , observers will be tested periodicall y to ensure their safety and RPA knowledge is up to company standards. Regarding the Operation of the Unmanned Aircraft Since the UAS weighs less than 55lbs the potential for bodily harm or property

damage is mitigated. All crew members involved in an operation will perform an inspection and preflight of the RPA prior to the flight. The RPA will not exceed a max speed of 87 knots. The UAS will not operate above 400’ AGL. The UAS will op erate within Visual Line of Site (VLOS) of the PI C at all times. The Minimum crew for each operation will consist of the UAS Pilot and the Visual Observer. 

### If the UAS loses communications or loses its GPS signal, the UAS will have the capability

to return to a pre

- determined location and land. Operations that AIS will take part in are aerial photography, aerial videography , and aerial data collection

. 

### Regarding the Exemptions Aerial Imagery Services seeks an 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) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)
Exemptions 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthi ness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Petitioner, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety underPart 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, we ight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.
14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAV, two

- in ch lettering will be impossible. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. 14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulat ory standard will exist for determining airworthiness. Given the size of the aircraft an equivalent level of safety will be provided by the PIC prior to each flight. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U. S.

-registered civil aircraft (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but becau se there is no room or capacity to carry such an item on the aircraft. 14 C.F.R. § 91.103: Preflight actionThis regulation requires each pilot in command to take certain actions before flight to insure the

safety of flight. As FAA approved rotorcraft fl ight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 14 C.F.R. §91.109: Flight instruction: Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.
Remotely pilot ed aircraft, by their design do not have fully functional dual controls. 14 C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests au thority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL. It wi ll however be operated in a safe and predetermined area. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the UAS provides approximately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length . Given the limitations on the UAS’s proposed flight area and the l ocation of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. L imiting UAS flights to 10 minutes would greatly reduce the utility of the purpose of the exemption

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropri ate and current airworthiness certificate. . . .(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or c ockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs less than 55 lbs and is operated remotely . As such, it is impossible to carry certification and registration documents or to display them on the aircraft

. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, e xcept as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Since these section s and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the Aerial Imagery Services . Maintenance will be accomplished by the operator in accordance with the flight manual and operating handbook. Conclusion I believe that allowing Aerial Imagery Services to operate in the National airspace under the restrictions granted following the 333 exemption will prove beneficial to the safety of others. Since Aerial Imagery Services operates UAV’s with a reduced paylo ad and are lightweight , the exposure to risk is greatly reduced. Additionally, with the implementation of our business in the local economy we hope to stimulate a niche in the Imagery and data collection industry by providing competitive jobs to pilots, o bservers and many other s
. Sincerely, Rylan Miller