## Documents

• Petition of Exemption

• Acknowledgement Letter

• UAS Flight Log

• UAS Maintenance Test Flight Log

• UAS Maintenance Log

• Copy of Rotary Pilot Certificate

### PETITION OF EXEMPTION

for Aerial Photography Solutions

a) Michael John Morris

3603 Luminoso Lane West Round Rock, TX 78681 ( 512)550

- 7040

M imorr3 2 @yahoo.com

b) Request exemption from part 21, subpart Hand Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b )(2), 91.1 03(b ), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91 .407(a)(l), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).

c) This exemption would allow Aerial Photography Solutions to operate the Phantom 2 quad copter unmanned aircraft system (UAS) to conduct aerial videography and cinematography to develop and

enha nce the marketing campaigns and operations of businesses as well as to provide any civil

assistance as requested

. This exemption would allow Aerial Photography Solutions to enhance

several industries to include: real estate, special events, construction, mining, site surveys, news gathering, roofing /chimney inspections , etc. Additionally, i t would also all ow businesses who would otherwise be priced out of aerial photography marketing opportunities to take advantage of this new

frontier

.

The extent of each relief requested will be as follows:

CFR 45.23(b) Display of marks; general

I request the U AS not to be either a certificated aircraft o r a certificated "experimental" aircraft. Exemption from display of marks is requested due t o its size and the airspace that it will operate in.

CFR 61.113(a) and (b) Private pilot privileges and limitations: Pilot in command

As I

, Michael John Morris , currently hold a commercial rotarcraft certif icate with instruments as well as a private single

- engine land certificate with a third

- class airmen medical certificate and currently a

UH

- 60L PIC fo r the US Army, I understand the importance to be knowledgeable of the National Airspace System (NAS). Howeve r, I request that a n on

- certificated pilot be able to operate the UAS

with direct and written discretion of a certificated pilot with proper ground, opera tion and airspace training that is established by that certificated pilot. This appointed pi lot would be tested in aircraft operation, maintenance, emergency procedures and th e NAS before assuming o peration of the UAS. A proper training program will be in place with documentation and tra ining logs.

CFR 91.7(a) Civil aircraft airworthiness

Given that the UAS will not require an airworthiness ce rtificate in accordance with 14 CFR part 21, I request exemption. Also, there is no FAA regulatory standard for determining the airworthiness of an

UAS. The manufac turer ’ s operating documents will be used by the operator to determine if the UAS is airworthy.CFR 91.9(b ) (2) Civil aircraft flight manual, marking, and placard requirements

Followed by exemption from CFR 45.23(b). Manufacturer ’ s operating manual shall be used and kept by the operator on location of UAS operations

.

CFR 91.103(b) Preflight action

While there is no approved airplane or rotorcraft flight m anual available for the UAS

, the manufacturers operating manual is requested to be used for p roper preflight. Runways and airports will not be used to deploy or recover t he UAS excluding them from the preflight/planning action.

CFR 91.109 Flight introduction; simulated instrument and certain flight tests

Although the UAS does not allow operation with a dual s et of controls, proper hands

- on training o f UAS operation will be given to any operationa l pilot by another pilot who has sufficient UAS operation hours. Simulated trai ning may be used for sufficient operational training. All pilots will be familiar with pr eflight actions, routine flight operations, and emergency procedures.

CFR 91.119 Minimum safe altitudes: general

Notification of all residing tenets on which property th e UAS is intended to operate on will be

coordinated in advance. Ten ets will be aware of t he exact time and area that the UAS will be operating in.

CFR 91.121 Altimeter settings

The UAS operator will maintain a GPS that will have d erived altitude capabilities to report feet AGL. Altitudes to be flown will be reported to local ATC before flight.

CFR 91.151(a) Fuel requirements for flight in VFR conditions

The UAS operator will land the UAS prior to the man ufacturer's recommended minimum level of battery power of 30 %. The UAS shows a low v oltage warning when 30% battery life is remaining. This provides ample time for the UAS o perator to land in an immediate safe area. Also, the UAS is equipped with an automated f unction that lands the aircraft immediately when a low battery is

detected.

CFR 91.203(a) and (b) Civil aircraft: certification required

Operations of the UAS prove to be above safety standards due to its size, weight, speed, and limited operating area that it will be operated in

.

CFR 91.405(a) Maintenance requi red

This only applies to aircraft with airworthiness certificat es. Maintenance of the UAS will be performed by the operator

. I f a discrepancy is found du ring pre

- flight it will be recorded on a "Maintenance Log" for personal history records.CFR 91.407(a) (l) Opera tion after maintenance, preventive maintenance, rebuilding,

or alteration

This only applies to aircraft with airworthiness certificates . Maintenance test flights will be performed after each maintenance discrepancy is corre cted as a safety precaution and r ecorded on a "Maintenance Test Flight Log" for personal history records.

CFR 91.409(a) (l) and (2) Inspections

This only applies to aircraft with airworthiness certificate s. Pre

- flight will be performed as a safety precaution by the operator using the outli ned pro cedures in the operating documents.

CFR 91.417(a) and (b) Maintenance records

This only applies to aircraft with airworthiness certific ates. Any maintenance performed on the UAS will be recorded on a "Maintenance Log" for personal history records

d) The UAS operations would provide more detailed and ad equate information to potential individuals, companies looking to relocate to the Central Texas area and promote economic growth overall. Also, the aerial videography would allow small busines s owners a more feasible option for marketing and adve rtisement over the high cost of manned rotary/fixed wing aircraft as in the past. Additionally

, the UAS operation increases the safety of patrons due to its small size and lack of

combustible fuel compa red to a large manned aircraft and reduces the ambient noise level helping to prevent noise complaints. Lastly, the UAS proves to be more ecologic al by emitting no e xhaust

fumes and requires no fossil fuels for operations.

e) UAS operations will not reduce the safety of other airbor ne pilots, operating pilots, or patrons that

are in an area of UAS operation. Conversely, the UAS increases safety as it reduces flight operations by rotary wing aircraft flying at low levels while conducting videography operation s which are conducive to a pilot b ecoming over task saturated and not recognize other flight dangers forcing them

into a da ngerous situation. Additionally the UAS size, weight, and speed do not pose a threat to the public or users of the NAS.

f) (1) Aerial Photography Solutions request exemption from the r equirements of part 21, subpart

Hand Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417 (a) and (b) of Title 14,

Code of Federal Regulations (14 CFR).

(2) This exemption will permit Aerial Photography Solutions to operate an Unmanned Aircraft System (UAS) for the purpose of conducting real esta te and business videography and cinematography throughout the Central Texas area to provide a more feasible and safer option for real estate and small business owners advertising and marketing.

g) Supporting operating documents are attached.

Michael J. MorrisNovember 14, 201 4

Aerial Photography Solutions 14 November 2015

To whom it may concern,

I am submitting this Petition of Exempt ion for the purpose of allowing businesses the financial ability to use videography an d cinematog raphy as a marketing tool for their busines se s, property, and or house. Als o, to showcase land and housing options for newcomers to the Central

Texas ar ea who may be unfamiliar to its geography

. I currently serve in the United States Army as
UH

- 60A/L Blackhawk Instructor and Maintenance Test Pilot . I have served in the military for 22 years and as a pilot for the last 16 years. I have over 3100 hrs of multi

- turbi ne engine rotary time as well 150 hours of fixed wing time . Throughout my years of flying, I am very aware of the demands and safety consideration of operating in the National Airspace System.

I write thi s letter hoping to show that my ex perience allows us to realize, understand and respect the very issues that the FAA is fa cing with drones for commerci al use. Our years of experience and knowledge make us m ore heightened and aware of the obstacles that lie ahead but make us respect the pro cess. As an aviation enthusiast, we look forward to developing the UAS into the marketing world.

Sincerely,

Michael J. Morris

Aerial Photography Solutions