Alexey Volobuev PO Box 22264 Honolulu, HI 96823
U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington DC 20590 Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) To whom it may concern: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14CFR Part 11, Alexey Volobuev, operatorofsmall Unmanned Aerial Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations to allow commercial operation ofasmall UAS, so long as such operations are conducted within and underthe conditions outlined herein oras my be established by the FAA as required by Section 333. Commercial operation small UAS, as described herein, which are equipped with cameras and sensors, would operate in the following manner: 1. Aerial photography and/orvideo for public

## ~nd/or**pri~ate** use including real estate, architecture, land surveying, engineering and other related professional activities.
2. Aerial photography and/orvideofor public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.
3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.
4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers
5. The abilityto offertraining to persons individually or belonging to both private and/or public Organizations that have interests in the use and application ofa UAS forthe purpose ofthe safe operation ofa UAS to enhance the safety ofthe National Airspace System (NAS) as well as for the protection ofthe persons and property.

As described fully below, the requested exe'mptiori would permitthe operation ofsmall UAS under controlled conditions in the NAS thatwould be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the. industry presently using conventional aircraft. Approval ofthis exemption wou,ld thereby enhance safety and fulfill theSecretary ofTransportation's (the FAA Administrator's) responsibilities to "

....establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system."

The name, phone, email and address ofthe applicant: Name: Alexey Volobuev Phone: {808) 343-8090 Email: alex.volobuev@live.com Address: PO Box 22264 Honolulu, HI 96823 Regulations from which the exemption isrequested: 14 CFR Part 21 subpart H 14CFR 45.23 (b) 14 CFR 61.113{a) 14 CFR 91.7 (a) 14CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119{c) 14 CFR 91.12114 CFR 91.151 (a) 14CFR 91.203 (a) 

### & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) 

### & (b)

The small UAS's Iwill be using are multi-rotorcraftweighing ho more than 551bs. including payload. Under normal conditions they operate at speeds ofno more than 45 Mph or39 Knots and have the abilityto hoverand move along avertical and horizontal plane simultaneously. They willoperate in line ofsight only and bythe exempted person onlyobeying all other local and federal laws. Given the small size ofthe UAS and the controlled environment provided the proposed operationswill adhere tothe Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grantofthe requested exemption is in the public interest. Accordinglythe applicant requests that the FAA grantthe requested exemption with minimum delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level ofsafety because operationswill further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1. The small UAS will weigh less.than 55 lbs.
2. Flights will be operatedwithin line ofsight ofa pilot and/orobserver.
3. Maximum flight time foreach operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve.
4. Flights will be operated at an altitude of no morethan 400feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.5. Minimum crew for each operation will consist ofthe small UAS Pilot in Command (PIC}, the Visual Observer (VO).when needed andmay include but not limited to a Camera Operator.
6. The small UAS pilot will be Alexey Volobuev ONLY not allowing any other person to operate the small UAS in a commercial capacity.
7. A briefing will be performed regarding the planned small UAS operations priorto each day's flight consisting ofall the days' production activities.
8. The PIC will obtain verbal/written consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100feet ofthe flight operation, and the radius may be reduced to 30 feet based upon anequivalent level ofsafety determination, as required underthe FOM. With the advanced permission ordirection ofthe FSDO, operations at closer range may be approved.
9. The PIC and VO will have been trained in operation ofsmall UAS and receive up-to-date information forthe particular small UAS to be operated and will be able to show upon request their

.. competent abilityto operate the small UAS and/orCamera.
10. The PIC and VO will be able to communicate byvoice atall times.
11.Written and/orverbal permission and permits will be obtained fromterritorial, state, county orcity jurisdictions, including lawenforcement, fire orotherappropriate**govern~ental** agencies when needed.
12. Ifthe small UAS loses communications or los,es.GPS signal, the small UAS will have the capabilityto returnto a pre-determined location within a designated location and land autonomously.
13. The small UAS will have the capabilityto abort aflight in case of unpredicted obstacles, weather, or emergencies.
14C.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 forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirementfor an airworthiness certificate, ·upon· consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular small UAS. In all cases, an analysis ofthese criteria demonstrates thatthe small UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificate withoutthe restrictions and conditions proposed. The small UAS to be operated hereunder is less than 55 lbs.fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a

### secured and designated area. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operatorand underthe requirements and in compliance with local public safety requirements. These safety enhancements provide agreater degree ofsafetyto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthat there is no credible threatto national security posed by the small UAS, due to its size, speed of operation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry a substantial external load. 14C.F.R. §45.23 (b). Markingofthe 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 orexperimental 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 small UAS will have no airworthiness certificate, an exemption may be needed as the small UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe smaiLUAS, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the small UAS marked on itsfuselage as required by §45.29 (f) where the pilot, observer and others working with the small UAS will see the identification ofthe small UAS as "Experimental." 14C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command. Pursuantto 14CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthatis carrying passengers or propertyfor compensation or hire. Our small UAS do not carry any pilots or passengers norpropertytherefore Iam seeking an exemptionto 14 CFR 61.113(a). Although helpful, a pilot's license will not ensure remote control piloting skills. The risks attendantto the operation ofsmall UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. Ifeel the operation and limitations set forth in the FOM will equate to the safe operation ofthe small UAS. 14C.F.R. §91.7(a): Civil AircraftAirworthiness. The regulation requires that no person may operate acivil aircraft unless it is in airworthycondition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining**airworthiness~** 

### Given the size ofthe aircraftfor maintenance and use ofsafety checklists priorto each flight an equivalent level ofsafety will be provided. 14C.F.R. §91.9 (b) (2): Civil Aircraft Fli$ht Manual in**~he** 

### Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.-registereq cjvil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof. The small UAS, given its size andconfiguration has

### no ability or place to carry such aflightmanual on the aircraft, not only because there is no piloton board, but because there is no roomorcapacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping theflight**manua~** 

### atthe ground control point where the pilotflying the small UAS will have immediate access to it.
14C.F.R. § 91.103: PreflightAction. 

### This regulation requires each pilot in command to take certain actions before flight to insure thesafe.ty

. offlight. As FAA approved rotorcraftflight manuals will not be provided forthe aircraft an exemption will be needed. The OPERATOR will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight.
14C.F.R. §91.109: Flight Instruction. 

### Section 91.103 provides that no personmay operate acivil aircraft (exc:;ept a manned free balloon) that is being used forflight instruction unlessthat aircraft has fullyfunctioning dual controls. Small UAS and remotely piloted aircraft, by theirdesign do not have fully functional dual controls. Flight control is accomplished through the use ofacontrol box that communicates with the aircraftvia radio communications. The FAA has approved exemptionsforflight training withoutfully functional dual controls for a numberofaircraft and forflight instruction in experimental aircraft:The equivalent level ofsafety provided by thefact that neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.
14C.F.R. §91.119: Minimum Safe Altitudes. 

### Section 91.119 establishes safe altitudesfor o.peration ofdvil 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 routeoraltitudes prescribed for helicopters by the FAA. As this exemption is for asmall UAS that is a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above,an elevated platform fromwhich filming is planned, an exemption may be needed to allowsuch operations. As set forth herein,the small UAS will never operate at higher than 400 AGL with theexception thatin circumstances where the small UAS is used to survey or photograph astructure whose height exceeds 400 feet AGL, the small UAS will not be operated more than 100' above the highest point on the structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir preobtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe small UAS as well as the location where it is operated. No flight will be taken without the permission of the property owneror local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations withaircraft or rotorcraft weighting far more than the maximum SSibs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition; the low-altitude operations ofthe small UAS will ensure separation between these small- UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119.
14C.F.R. §91.121 Altimeter Settings. 

### This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimete(thatis set "

...to the elevation ofthe departure airportoran appropriate altimetersetting ·

### available before departure." As the small UAS may not have a barometric altimeter, but instead a GPS altitude read 

### out, an exemption may be needed. An equivalent level ofsafetywill be achieved by the operator, pursuantto the safety check list and live flightdata monitoring, confirming the altitude ofthe launch site shown on the GPS altitude inditatorbefore flight.
14C.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 underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flyto the first point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least 30 minutes; or (2) At night, to fly afterthatfor at least 45 minutes." The battery powering the small UAS provides approximately 30 minutes ofpowered flight. To meetthe 30 minute.reserve requirement in 14 CFR §91.151, small UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the small UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longertime frame forflight in daylight ortwilightVFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) fa'lls within the.scope ofprior exemptions. Operating the small UAS, in atightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engenderthetype of risks that Section 91.151(a} was intended to alleviate given the size a'}d speed ofthe small UAS. Additionally, limiting small UAS flights to 10 minutes would greatly reduce the utility forwhich the exemption will be granted. Applicant believes thatan equivalent level ofsafety can be achieved by limiting flights to 30 minutes or25% ofbattery power- whichever happens first. This restriction would be more than adequate to return the small UAS to its planned landing zone from anywherein its limited operating area. 14C.F.R. §91.203 (a)and (b): Carrying Civil Aircraft Certification and Registration

. •· I ' .

. 

### The regulation provides in pertinent part: (a) except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthefollowing: (1) an appropriate and current airworthiness certificate

.

. . . (b) No person may operate acivil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers orcrew. The small UAS fully loaded weighs no more than 55 lbs. and is operated withoutan onboard pilot. As such, there is no abilityor place to carry certification and registration documents orto display them on the small UAS. An equivalent level ofsafety will be achieved by keeping these documents atthe ground control point where the pilot flying the small UAS will have immediate access to them; to the extentthey are applicable to the small UAS.
14C.F.R. §91.405 

### (a); 407 (a) (1); 409 (a) (2); 417(a) 

### &(b): Maintenance Inspections
. . ' 

### These regulations require that an aircraft operatororowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese section and Part 43 apply onlyto aircraftwith an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flightmanual andoperating handbook. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry asmall,payload and operate only in restricted areas for limited periods of time. Ifmechanical issues arise the small UAS can land immediatelyand will be operating from no higher than 400 feet AGL. The operatorwill ensure thatthesmall UAS is in working order priorto initiating · flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliarwith the aircraft and best suitedto maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. Ah equivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordancewith the small UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the operatorwill ensure thatthe small UAS is in working order priorto initiatingflight and perform required maintenance needed. 

### Public Interest Granting Alexey Volobuev's petition for exemption furthers the public interest. National policy set by Congress favors early integration ofUAS intothe NAS in controlled, safe working environments such as proposed in this petition. By granting this petition, the FAA will fulfill Congress's intent ofallowing UAS to operate safely in the NAS before completion ofthe nilem-aking required underSection 332 ofthe Reform Act.
Moreover, use of UAS will impra,ve efficiency and reduce costs for customers by reducing the time and expense necessary to collect aerial imagery. The use ofthe UAS proposed here will also decrease safetyrelated incidents involvingtraditional aircraft. The public has an interest in reducing the hazards and emissions associated with alternate use of heliCopters and small airplanesto conduct similar imaging operations.
Alexey Volobuev's intended uses forthe UAS will have real-woi-ld benefits forthe engineering and

. I

. • ' construction industries and the public by reducing the costs and enhancing thesafety ofaerial imaging and data collection. 

### Privacy
All flights that occur over private propertywill be done only with the owner's consent. All flights will be conducted in accordance with any federal, state or local laws regarding privacy.



### Radio Frequencies Radio frequencies used will be those allotted by the FCC 'for data transmission and vehicle control in unlicensed frequency bands. All devices used will comply with FCC usage and emissions regulations



### Small UAS Information Small UAS's to be used are as follows:1. DJI Phantom 3 Professional/Advance Weight (Including Battery and Propellers) 1280g Diagonal Size (Including Propellers) 590 mm MaxAscent Speed 5 m/s Max Descent Speed 3 m/s HoverAccuracy • Vertical:+/- 0.1 m (when Vision Positioning is active) or+/- 0.5 m • Horizontal:+/- 1.5 m Max Speed 16 m/s (ATTl mode, no wind) 

### 2. DJIInspire Model T600 Weight (Battery Included) 2935 g Hovering Accuracy (Gps Mode) Vertical: 0.5 m Horizontal: 2.5 m MaxAngular Velocity Pitch: 300°/S Yaw: 150°/S MaxTilfAngle 35° MaxAscent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATil mode, no wind) Max Flight Altitude 4500 m MaxWind Speed Resistance 10 m/s Max FlightTime Approximately 18 minutes Motor Model DJI 3510 Propeller Model DJI 1345 Indoor Hovering Enabled by default OperatingTemperature Range -10° to 40° C Diagonal Distance 559 to 581 mm Dimensions 438x451x301 mm 3. 3DR Solo Flight time: 25 minutes; 20 minutes with payload* Range: .5 miles** (.8 km) Max speed: 55 mph (89 km/h) Max ascent speed: 10m/sinstabilize mode; 5 m/s in "fly" mode Max payload: 420 g Max altitude: 400ft. per FAA regulation, user adjustable (122m) Motors: 880 kV Propellers: 10"diameter4.5" pitch self-tightening (24 em diameter 144 em pitch); glass-reinforced nylon Communication: 3DR Link secure Wi-Fi network Frequency: 2.4 GHz Weight: 3.3 lbs. (1.5 kg) 

## I 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal Dimensions: 10 in. tall (25 em), 18 in. (46 em) motor-to-motorFlight battery: Lithium polymer 5200 mAh 14.8 Vdc
4.3DR Iris Plus Total weight (with battery): 1282g Dimensions: Height 100mm, Motor-to-motor550mm Under still airthe maximum speed is about 40mph (17.9 m/s) Maxflight time: 16-22 minutes* (*depending on payload) Payload max capacity: 400g (.81bs.) GPS Mode: 3DR uBiox GPS with compass (LEA-6H module, 5 Hz update) The 3DR Iris+ has the abilityto hover and move along avertical and horizontal plane simultaneously. Four 950 kV motors, four 9.5 x 4.5 T-Motor multirotorself-tightening propellers Intelligent Flight Battery: 3S 5.1 Ah 8C lithium polymer The 3DR Iris+ remote controller has an operating frequency of915 MHz fortelemetry, 2.4 GHz for control. Maximum transmission distance: up to 1 km (.6 miles) (outdoors and unobstructed)
Additional Information
The applicant, Alexey Volobuev, currently holds a Private Pilot Certificate (currently 80+ hours operating single engine fixed wing aircraft)and current 3rd class medical certificate. Alexey Volobuev has an indepth understanding ofthe capabilities and safety concerns involved in using this technology as an asset to the community. Satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2012 provide more than adequatejustification forthe grant ofthe requested exemptions allowing the commercial operation ofthe applicant's UAS. 

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