Edward J. Smith W1 0792 W ildwood way Poynette, W I 53955 608

- 770

- 5678 eddarde1@gmail.com

Dear Sir or Madame,

Please see the below exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations.

**(B) Specific Sections of 14 CFR** Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H 14 CFR 45.23(b) 14 CFR 61.113(a) and (b) 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) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2) 14 CFR 91.417(a) and (b)

**(C) Extent of Relief I Seek** Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Edward Smith, operator of Unmanned Aircraft Sy stems (UAS), hereb y applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may be established by

the FAA as required by

Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional serv ices in the following areas: 1. Aerial photograph y and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, cinematograph y and news gathering. 3. Aerial inspection/photograph y of residential/commercial structures under contract with the owners or local government authority

. 4. Aerial inspection/photograph y of re sidential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency o r natural disaster onl y when the local authorities or government has requested it by contract or donation. 6. Training to persons individually or belonging to both private and/or public organizations to increase awareness and improve safet y for current an d future UAS operations within the NAS. As described fully

below, the requested exemption would permit the operation of designated UAS as set forth in this document under controlled conditions in the NAS that would be a) limited b) controlled c) predetermi ned and d) safe. Approval of this exemption would increasepublic awareness of UAS operations and enhance safet y to aid in fulfilling the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe o peration of such aircraft s ys tems in the national airspace s ys tem.”

**(D) Reasons Why Granting My Request Would be in the Public Interest** Aerial photograph y and has been around for a long time through manned fixed wing aircraft and helicopters. For small bu dget productions the expense of such aerial photograph y and videograph y is cost prohibitive. Only larger companies can afford to absorb such expense. Manned aircraft pose a threat to the public through the potential of a catastrophic crash. M y sUAS poses n o such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress has alread y proclaimed that it is in the public’s interest to integrate commerciall y flown sUASs into the national airspace s ys tem, hence the pass ing of the Reform Act. Granting my exemption request furthers the public interest through academic/visual awareness of the photograph y and videography fields throughout the Grand Rapids area. M y ultra

- lightweights UAS is battery

powered and creates no emis sions that can harm the environment. The consequence of m y ultra

- lightweights UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heav y, contain combustible fuel and can cause catastrophic devastation to the public. The p ublic’s interest is furthered b y minimizing ecological and crash threat by permitting aerial photograph y and videography captured through my battery operated ultra

- lightweights UAS's. Permitting me to immediately fly within national air space furthers econ omic growth. Granting
my exemption request substantially furthers the economic impact for the Madison, WI area for companies looking to use aerial photograph y and videograph y, both of which serve as a stimulus to the community

.
**(E) Reasons Why Granting th e Exemption Would Not Adversely Affect Safety**  Given the small size of the UAS’s involved and the restricted controlled environment within which they

will operate, the applicant fits within that zone of safety (an equivalent level of safet y) in which Congre ss envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediatel y. Also due to the size of the UASs and the controlled areas in which the relevant UASs will operate, approval of the application presents no national securit y issue. Given the following, the grant of the requested exemptions is clearly in the public interest: Edward Smith proposes that the exemption requested herein appl y to civil aircraft that have the characteristics and that operate with the limitati ons listed herein. These limitations provide for an exceptional level of safety to operations. These limitations and conditions to which Edward Smith agrees to be bound when conducting commercial operations under an FAA issued exemption including: 1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of operator. 3. Maximum total flight time for each operational flight will be 30 minutes. 4. Flights will be terminated at 15% battery power reserve. 4. Flights will be operated at an altitude of no more than 400 feet AGL 5. UAS operator will be trained and certified in the proper safety and operations of the UAS. 6. The UAS will only

operate within a controlled area as defined in the Procedures. 7. The operator will post advisor notice around the controlled area.8. The operator will have been trained in operation of UAS generally and received up

- to

- date information on the particular UAS to be operated as required. 9. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre

- determined location within the Security Perimeter and land. 10. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. **(F) A summar y you can publish in the**  **Federal Register (1) The Rules From Which I Seek**  **Exemption** 14 CFR 21 subpart H 14 CFR 45.23(b) 14 CFR 61.113(a) and (b) 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) 14 CFR 91 .405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2) 14 CFR 91.417(a) and (b) **(2) A Brief Description of the Relief I Seek** Approval of exemptions allowing commercial operations of sUASs in the the aerial photography and videograph y industry will enh ance safet y b y reducing risk associated with conventional aircraft operations and other means of elevated remote sensing involving persons. The public benefit served b y approval of this petition is increased awareness of characteristics of difficult imagin g targets. A sUAS weighing fewer than 11 kg and powered b y sealed batteries eliminates virtually all associated risk inherent in operating conventional aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they wo uld be able to collect needed data.The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exe mpting the applicant from the requirements of Part 21 and allowing commercial operations. The UAS that I will be using are the DJ I Phantom 3 Pro, DJIInspire 1 Pro Accordingl y, the applicant respectfull y requests that the FAA grant the requested exemption and is prepared to modify

or amend an y part of this request to satisfy the need for an equivalent level of safet y. I look forward to working with your office. Please contact me at any time if additional information or clarifications is needed.

Sincerel y, Edward Smith