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 flying
quad 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 controlled 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 photography 
usage

as recorded flight data and other information gained 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 Administrator’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 established 

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 the 

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 economic 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 Iwinskis Drone 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 Iwinskis 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 

commercial

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 like 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 in 
determining the

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

Considerations include:

The weight, size, speed and overall 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 Drone 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 camera 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 UAS 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/Medical helicopters, etc.) and 

prepared to

land/abort immediately to the nearest and safest ground point should a 
manned

aircraft approach my location or we suspect manned aircraft may approach 

near

my location. Our UAS is capable of vertical and horizontal operations, 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 hundred 

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 minimum 

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 exercise 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

airspace 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 airspace 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. How Greg Iwinskis Drone Service’s Request Will Benefit the

Public As A Whole:

Aerial 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 videography 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 and 
around 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 UAS 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

permitting 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 the 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 the community.

V. Reasons Why Greg Iwinskis Drone Service’s Exemption Will Not

Adversely Affect Safety Or How The Exemption Will Provide a

Level of Safety At Least Equal To Existing Rule:

Greg iwinskis Drone Service’s, exemption will not adversely affect safety. 

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. In
addition,Greg Iwinskis Drone Service, submit the following representations 

of

enhancements to current aerial 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 in 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

exceeding existing rules. It is important to note that absent the integration 

of

commercial UAS into our national airspace system, helicopters are the 
primary

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 greatly 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 Summary 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, 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 

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 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.

Greg Iwinskis Drone Service’ current 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

certifications 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: Marking 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 current 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 the 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 

UAS
will 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 speed 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 “have [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 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, 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 of 
safety

pursuant to Section 333 of the Reform Act. The FAA is authorized 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 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 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, maintenance 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 Iwinskis Drone Service seeks an exemption from

the following 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 community 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 relies 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 contain 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 public 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 currently 

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 limited 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 in
sharing 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 waterproof 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, 150 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 capabilities can be 

observed

through a series of manufacture videos explaining the Mariner through

this link ( 

http://fpvfactory.com/buy-commercial-drones-quadcopters/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 gross 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 characteristic,

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 

Drone
Service 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 videos 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 AMA
standards 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 prove 

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, 

damage 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 markings 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 mountains, golf course, 

manmade

lake or other attractions not possible through ground level video recording 
or

photography. Petitioner requests waiver for this condition to allow 

reasonable and

responsible aerial video/photography in congested areas of subdivisions 

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 charged 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 that 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 limitation 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 VSOL will be rare if

ever needed.

Airman Certification:

Petitioner has taken helicopter flying leessons and has 1 hours flight time 
and 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