**FAA**

**Docket Management Facility U.S. Department of Transportation**  **1200 New Jersey** 

**A venue, SE**  **West Building, Ground Floor, Room W12 -**  **140 Washington, DC 20590** 

**Dear Exemption Manager, Introduction:**  **I am submitting a Petition for Exemption for Unmanned Aircraft Systems operations. I am seeking**  **this exemption primarily so that I may start a small business w herein I am able to sell**  **UA S/UA**  **V/RPA footage from my DJI Phantom 3 to real -**  **estate companies. Other applications are of course possible how**  **ever this is my primary focus at this time.**  **It is my understanding that I w ill**  **not be able to create a small business w ithout this exemption.**  **As of today, I am delaying the creation of my company, w hich will be named “I**  **- Spy**  **”, until such time as I know**  **it is legal to sell our product. I w**  **ant to do the process by the book, and have no intention of operating outside the law**  **. A t the same time, the current restrictions completely**  **preempt this venture from taking place. Thus the reason I fervently ask for this exemption. A fter**  **explaining w ho I am and what I plan to do w**  **ith the exemption, I am sure you w ill agree I am a**  **qualified candidate w ho is focused on safety.**  **About me, the pilot: I currently w**  **ork as RPA (UAS/V) pilot w**  **ith the 119WG/178RS in Fargo, ND wh**  **ich is also w h**  **ere I would like to operate my small RPA**  **. I have w orked in the RPA field since 2007, first as an**  **intelligence analyst ,**  **until November 2013 w hen I began my transition to an RPA pilot. I received**  **my RPA w**  **ings (A ir Force AFSC 18A) in the summer of 2013 and ha**  **ve been flying real w orld**  **missions ever since on a daily basis.**  **I have over 700 hours of Pilot in Command (PIC) time fly ing missions all over the w**  **orld with the MQ**  **- 1 Predator. As a reconnaissance unit w**  **e are consistently training, updating and improving our**  **tactics, and developing our airmanship. As an RPA pilot, I am held to the same**  **phy sical and**  **operational standards that all A ir Force pilots are.**  **Exemption request :**  **My request is for a w**  **aiver of the sections identified below in an effort to operate a**  **UA S in use of**  **Commercial applications for Real Estate and Marketing Purposes, and live sporting events.**  **This request specifically serves the public and economic interest to aide in the areas stated above.**  **The granting of this exemption w ould make**  **logical sense because of my professional approach to UA** **S operations, my clear understanding of FAA rules, my aw**  **areness of operational and restricted airspace,**  **my experience as an RPA pilot, my aw areness of and ability to react to emergency**  **situations, and my attitude of safety first w**  **hen it comes to flight operations.**
**I believe w ith the granting of this exemption and the addi**  **tional operational experience I wi**  **ll gain from**  **flight operations that I w ill be able to have a much larger impact for the future of UAS. More**  **flight experience now w**  **ill be invaluable for us to assist the general public in the future as they embark**  **into UAS operations.**
**I w ould currently be seeking ex**  **emption of: Section of 14 CFR: parts 21 Subpart H, 27, 45.23(b), 45.27(a), 61.113(a) and (b), 61.133(a),**  **91.7(a), 91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.319(a) (1), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) a**  **nd (b) If I have erroneously omitted any other relevant section for our intended operations, please feel**  **Free to suggest the missing section(s). Suggested Public Federal Register Summary**  **:**

**"The petitioner is seeking an exemption to operate unmanned aircra ft systems (UAS) w**  **ith a maximum w**  **eight of less than 55 pounds to perform Professional Marketing Services, Real Estate and Live Sporting Events, Etc. Data gathered may include still and moving images captured w**  **ith onboard cameras."**  **UA S Description:**  **I am a sking for an exemption for a UA** **S up to 55 pounds because that is currently w hat the**  **standard exemption covers. How ever, at this time I only have one UAS, a Phantom 3 by DJI w**  **hich is much smaller than 55 pounds.**  **In the event a loss of communications occur s the craft w**  **ill rise up vertically to a safe height before beginning an automatic return to home function. The control signal may be reconnected**  **in flight and the pilot can take over safe operations again if communication is reestablished. How**  **ever in the case of a GPS failure the craft w**  **ill be able to be manually flow n to a safe landing**  **by the pilot.**  **The craft operates electrically , carries no flammable fuel, has an integrated GPS pilot system,**  **provides location information along w ith height AGL, speed,**  **battery life, has programmed no -** **fly zones for controlled airports, and provides direction of travel and distance from the pilot.**  **Flight Operations:**
**I am w ell aware of conducting safe flight operations and planning flight paths that minimize any**  **over flight of crow**  **ds.**
**An y flight operations in town environments w**  **ould typically be for close air support for very focused**  **events such as sporting, or real -**  **estate marketing. These operations occur in a very limited area and w**  **ould not need to overfly densely populated areas in general. Operations w**  **ould be more vertical in nature above the specific event. There w**  **ould be no need in my opinion to ever fly**  **above 200’ AGL. Our proposed public safety UAS operations are typically**  **conducted at low altitudes less th**  **an 200’ AGL (w**  **ithin Class G airspace), not over crow ds, and not near airports. Additionally**  **, there w ill be**  **no need for any flights including high speeds. Certainly slow**  **er than 30mph but most often at walking speeds. Flights w**  **ill end w hen**  **battery reserve re aches 25 percent. Operations w**  **ill not occur under IFR conditions. In addition, preflight and post**  **- flight checklists and UA** **S examinations will help detect any abnormalities prior to flight and after flight. Any UAS unable to satisfy safety**  **checklists w ill b**  **e removed from service until the issue can be resolved. Granting this request would not adversely affect safety since operations w**  **ould be in accordance w ith current UAS**  **rules. Section 333 Compliance and Appropriateness:**  **Based on the size of the craft, ex perience of the pilot, and operational goals, this request**  **appears to be w ell suited for approval using the criteria outlined in Section 333 of the FAA**  **Modernization and Reform Act of 2012 and w ill**  **move safe flight operations forward in**  **accordance wi**  **th the intent of Section 333. Ongoing Efforts:**  **We are also keenly aw are of the new** **issues involved in UAS public safety operations and w ould**  **greatly like to assist public safety departments to fly with commonsense and safety first in mind. Many**  **depart ments I have seen are under the misperception small UAS craft are toys, w**  **hich they are not. With your help w**  **e hope to obtain this exemption in order to use my exempted flight experience to help any agencies get off on the right foot, learn w**  **hat they don't kno** **w, and help**  **them to move forw ard to operate safer w**  **hile they utilize the UAS.**