Lucas Bucholz

729 SE Manley

Bend, OR 97702

Cell (541) 480-0299

Email: Lucas.bucholz@gmail.com

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 2012

Dear Sir or Madam,

In accordance with the FAA’s

Guidelines for Submitting a Petition for Exemption under

section 333 of the FAA Modernization and Reform Act of 2012, I Lucas Bucholz,

referred to hereafter as the petitioner, request exemption from the following

sections of

Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1);

91.409 (a)(1); 91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in

airspace

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial

photography, cinematography, videography, and other flight operations that

could be

performed safely and more cost effectively with the use of small UAS at low

altitude

within the U.S. national airspace system as compared to a manned aircraft.

Operations

will be performed only at the request of and with the authorization and

permission of clients or their authorized agents in order to facilitate commerce

and raise awareness of the beneficial uses of small unmanned air systems.

So long as such operations are conducted within and under the conditions

outlined herein

or as may be established by the FAA as required by Section 333.

The FARs

The petitioner seeks exemption from the

above-mentionedFARs for the following reasons;

61.113(a) & (b);
The petitioner requests relief in order to facilitate the utilization of an FAA

licensed

and current Private Pilot (Ty Baxter) with the addition of a Lucas Bucholz as the

visual observer. All pre-flight inspection, maintenance and flight logs will be saved

and made available to the FAA and Secretary of Transportation (SoT) for review;

with the purpose of safely integrating civil UAS operation in the National Airspace

System.

91.119(c)

The petitioner requests waiver for this condition to allow reasonable and

responsible operations in areas of subdivisions and neighborhoods if required. The

petitioner will primarily operate the UAS between ground level and 200 feet. The

UAS will be operated over designated properties with the owner’s consent and

while maintaining a safe distance from persons. The petitioner will compile flight

data from the logs. This data may assist the FAA in development of regulations

for commercial operations in low-risk, controlled environments.

91.121

inapplicable since the UAS does not have an altimeter and instead utilizes

electronic GPS with a barometric sensor for altitude information.

91.151(a)

The UAS provides battery power remaining in percent to the PIC. The

UA batteries provide approximately 25 minutes of powered flight. Information

provided in the operating documents discusses procedures regarding remaining

battery power management. Those documents contain a condition in which the

PIC will initiate a landing procedure when battery remaining reaches a specified

level. Given the limitations on proposed operations and the location of those

proposed operations, The FAA found that a reduced minimum power reserve for

flight in daytime VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b)

The petitioner proposes to inspect and ensure that the UAS is in a condition for

safe flight in accordance with the operating documents. The FAA found that

adherence to the petitioner’s operating documents and the conditions and

limitations specified, describing the requirements for maintenance, inspection,

and recordkeeping, were sufficient to ensure that safety would

not be adversely affected.

The UAS

DJI Inspire 1 pro- We have recently added this UAS to our fleet.

Weight 2932g

Dimensions 438x451x301 mm

All of the same parameters below apply to this UAS
The S500 is a custom built quadcopter specifically for the use of filming and

photography with a weight of less than 44 Ounces (1242g) designed primarily to

carry aloft a high definition camera. The flight controler is a DJI naza MV2 which

is the leader in uav technology. I have attached the manual for you to look at.

The rest of the parts are also all DJI products. I wanted to have something built

that was up to the standards of a commercial uav but with the extra features that

will help in being safer as well as more options for the PIC and the observer to

better help clients needs. It has an maximum speed of less than 30 knots

(15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It

is powered by four electric motors with a distance between motors of less than

18.7 inches (475mm). It utilizes an internal inertial measuring unit (IMU) with

integrated barometric sensor augmented with global positioning system (GPS) to

maintain its geospatial orientation and position. It is controlled primarily through

an FCC certified radio control (RC) unit. Real time video and telemetry

information is transmitted back to a ground control station allowing the operator

and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance

from PIC, camera imagery, and control camera angle. It has failsafe modes of

operation for either loss of RC or GPS signal. Altitude can be limited by the

onboard flight controller and maximum altitude can be preprogrammed by the

PIC. Maximum altitude will always be programmed at 200 ft. Battery life limits

flight times to approximately 25 minutes. The onboard flight controller will warn

the pilot via telemetry and external lighting cues before reaching a low battery

state. An automatic termination of flight and controlled automatic landing will be

initiated when the battery reaches a predetermined low state. It is anticipated

that flights will usually last less than 15minutes.

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and

Limitations

section and believes that the procedures specified therein are reasonable and will

be

utilized in order to manage and mitigate risk and ensure public safety. A preflight

checklist will be developed and employed to ensure that the UA airworthiness will

be

verified before launch. Airworthiness will be maintained by performance of routine

inspections before each flight, maintaining flight and maintenance logs to record

time on

failure prone components. These documents will be made available to the FAA

and SoT to assist in future implementation of safety standards and regulations.

The petitioner will only operate the UAS over designated properties with the

owner’s consent. Flight plans

will be predetermined to limit the UASs flight time and limit safety concerns. The

petitioner will take into account distance from persons and potential flight

obstacles prior to operating the UAS. UAS operation will always be within VLOS of

the PIC and the observer.
Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned

aircraft

of greater proportions, carrying a crew and flammable fuel. Additionally, use of

the UAS in order to facilitate commerce could lead to economic growth.

Operations for this

petition will enable service for property owners or their designees seeking an

enhanced

perspective for characteristics, amenities, and benefits of their desired

photographic

subjects that cannot be displayed through ground level videography/photography.

Aerial

photography is a valuable marketing tool that can lead to increased commerce

and

enhance personal photography. Aerial surveying and inspections can increase

work site efficiency, improve volumetric estimations and reduce risks. The

petitioner will provide clients with photographic data for these purposes on a ‘for

hire’ basis acting as an

independent contractor. A visual observer will be utilized. Flight data including

A flight time, Control Unit operation time, incident, accident, and details

concerning any

deviations from normal operations will be available to FAA for use in collecting

data

regarding the use of UAS as part of this application. This data may be submitted

to FAA

via traditional means or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial

photography,

cinematography, videography, inspections and surveying other flight operations”.

The reason for such a general and broad based request is that the petitioner

wishes to utilize a business

strategy of horizontal integration and maximize economies of scope in order to

capitalize

on opportunities as they may arise in the future without the long turnaround time

associated with additional exemptions.

Lucas Bucholz