November 16, 2015

Robert Hannau

813 NE 97 th Street Miami Shores, FL 33138

Mobile #: 305

- 609

- 4974 Email: Bob.Hannau@gmail.com

U.S. Department of Transportation Docket Management System West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave., SE

Was hington, DC 20590

RE: Request for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11 of the Federal Aviation Regulations.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the

“Refor m Act”) and Title 14 CFR Part 11, I, Robert Hannau, seek exemption from Federal Aviation Regulations (“FARs”) listed below to allow the commercial operation of Small Unmanned Aircraft Systems (“sUAS”) also list below for th e purpose of aerial video and

sti ll photography

, marine and real estate photography and site inspections

, videography and still photography of social events, such as weddings, with the sUAS to remain at least

500 feet from all nonparticipating persons as noted in the reference exemptions listed

below.

Operators Contact Information:

Name: Robert Hannau

Address: 813 NE 97 th Street, Miami Shores, FL 33138

Mobile: 305

- 609

- 4974

Email: Bob.Hannau@gmail.com

List of FARs requesting exemption: Title 14: Aeronotics and Space

! § 61.23(a)

! §61.113(a)

! § 91.119(c)

! § 91.121

! § 91.151(a)

! § 91.405(a)

! § 91.407(a)(1)

! § 91.409(a)(1) & (a)(2)

! § 91.417(a) & (b)List of sUAS

! DJI Phantom 3 Professional

! DJI Inspire 1 Pro / Raw

! 3D Robotics Solo

! 3D Robotics X8+

References: 1) FAA Exemption No. 13574, Regulatory Docket No. FAA

- 2015

- 3701, petition by Mr. Mark Griggs, GDI, LLC 2) FAA Exemption No. 13567, Regulatory Docket No. FAA

- 2015

- 3174, petition by Mr. Jonathan Rupprec h t, Esq., Counsel for Aerialpixels, LLC 3) FAA Exemption No. 13565, Regulatory Docket No. FAA

- 2015

- 3569, petition by Mr. Patrick Belanger, The 111 th Group, Inc. 4) FAA Exemption No. 13507, Regulatory Docket No. FAA

- 2015

- 3644, petition by Mr. Nicholas Bolland, Panoptic Works, Inc. 5) FAA Exemption No. 13506, Regulatory Docket No. FAA

- 2015

- 3645, petition by Mr. Shaun Nathan Cap ps, Top Flight Digital Media LLC

The operator, Robert Hannau, will maintain an equivalent level of safety or no adverse impact on safety by following the safe operational parameters of the sUAS manual s , FAA

rules and FAA Conditions and Limitation s noted i n the exemptions in the References list

above. The sUAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel. Operations will be performed safely and more cost effectively with the use of sUAS 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 and their authorized agents in order to facilitate commerce an d raise awareness of the beneficial uses of small unmanned air systems. So long as such oper ations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and p roposed by, Robert Hannau , are drawn from

references 1) to 5) above.

**The FARs** I, Robert Hannau, request exemption from the above mentioned FARs for the following reasons:

**§61.23(a) Medical Certificates:** Exemption Nos. 13574, 13567, 13565, 13507 and

13506 and others show that a U.S. driver’s license could be used in lieu of the medical certificate and provides and equivalent level of safety. I am likewise seeking the same set of previously granted restrictions.

**§61.113(a) Private Pilot Privileges and Limi tations**  **:** Sub

- section §61.113(a) limits private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operati ng the aircraft to have a sport pilot license or greater rather than a commercial pilot’s license to operate the sUAS. A visual observer (“VO”) will be used at all times while under this requested exemption as noted in exemption nos. 13574, 13567, 13565, 1 3507 and 13506.**§ 91.119(c)**  **Minimum Safe Altitudes:** As discussed in Exemption No. 13506, the regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the ai rcraft will be operating at a maximum of 400 feet AGL, operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles and structures unless specific permission is granted by the owner/controller of said people and prope rty and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that is does not present an undue hazard.

**§ 91.121**  **Altimiter Settings:** As noted in Exemption No. 13507, the sUAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI or 3D

Robotics s UA S will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the

s UA S to the controller for act ive monitoring of the flight path. This altitude information,

combined with the visual observer will ensure a n equivalent le vel of safety equivalent.

**§ 91.151(a)**  **Fuel Requirements for Flight in VFR Conditions:** The regulation provides that no person may beg in a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30

minutes. The s UA S is battery operated and the maximum duration of flight fr om a single

batte ry charge is approximately 20 minutes with a reserve. To provide an equivalent level of safety, as noted in exemption nos. 13574, 13567, 13565, 13507 and 13506 (and others), flight will not begin unless (considering wind and forecast weather conditions)

th ere is enough available power for the sUAS to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

**§ 91.405(a). 91.407(a)(1). 91.409 (a)(1) & (2). 91.417(a) &**  **(b) Maintenance,** 

**Preventive Maintenance and Alterations :**  The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 requi re that the aircraft be

“ approved for return to service by a person authorized under 43.7” after maintenance and inspection.

It is my intention that the PIC perform maintenance and inspection of the aircraft and “ be

authorized to approve the aircraft for return to service.” A Pre

- Flight Checklist to be performed by the PIC before every flight will ensure that the aircraft is in an airworthy

cond ition prior to every flight. I n addition conduct detailed inspections after every two hours of flight. Maintenan ce performed by the PIC is limited to replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with § 91.417. I feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.**Public Interest** The use of sUAS on aerial photography operations can significantly reduce the risk to photographers and participants. sUAS can inspect, photograph, and collect data on hard to get to areas that otherwise would require direct access or manned aircraft with much larger and expensive photographic equipment. Th e sUAS I propose to fly in this appl ication are less than 55 pounds and carry no combustible material on board, as opposed to the much larger conventionally powered small aircraft. The sUAS compared to manned aircraft presents a marked safet y increase for the participants and reduces the environmental impact by dramatically decreasing the energy used for aerial imaging and

data collection.

I, Robert Hannau , will also make the s UAS and myself available to local first responder organizations (for no charge) such as fire departments, local law enforcement, etc., to perform search and rescue operations, or other similar events as directed by authorities.

In addition

, the use of the s 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 photography. Aeri al photography is a valuable marketing tool that can lead to increased

commerce for my clients

.

A visual observer wil l be utilized at all times the s UAS is performing duties for compensation and the PIC wil l hold the proper documents. Liability insurance will be obtained commensurate with the granting of this request for exemption. Flight data including s UAS flight time, Control Unit operation time, incident, and details will be recorded for each flight and made available to the FAA upon request

. Any devia tions from normal operations will also be recorded and made available to the FAA.

**Proposed Operations** Proposed operation s are for the purpose of aerial video and still photography, marine and real estate photography and site inspections, videography and s till photography of social events, such as weddings, with the sUAS to remain at least 500 feet from all nonparticipating persons as noted previously.

In seeking this exemption

, operations will be conducted per the manufacturer of the sUAS, conditions and limitations of the FAA and local government. Following are the proposed operations:

1. The sUAS may not be flown at an indicated airspeed exceedin g 55 knots.

2. The s UA S must be operated at an altitude of no more than 4 00 feet above ground

level (AGL), as indicated by the procedures specified in the operating documents

unless a special request is made and approved by ATC. All altitudes reported to

ATC must be in feet AGL.3. The UAs must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any device

other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical

certificat e or valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government

. 4. All operations must utilize a Visual Observer (V O). The V O may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The V O and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his o r her designation for the duration of the flight. The PIC must ensure that the V O can perform the functions prescribed in the operating documents.

5. The V O must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and other ground based obstacles/obstructions and is

not permitted to operate the camera or other instruments.

6. The operating documents and the grant of exemption must be accessible during

s UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the

conditions and limitations c ontained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibili ty to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator deter mines that

any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its g rant of exemption. The FAA’s UAS Integration Office (AFS80) may be contacted if questions arise regardi ng updates or revisions to the operating documents.

7. Prior to each flight the PIC must inspect the s UAS to ensure that it is in a

condition for safe flight. If the inspection reveals a condition that affects the safe operation of the s UAS, the aircraft is p rohibited from operating until the necessary maintenance has been performed and the s UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records.

8. Any s UAS that has undergone maintenance or alterations that affect the s UAS operation or flight characteristics, e.g. replacement of a flight critical component,

must undergo a functional test flight. The PIC who condu cts the functional test flight must make an entry in the aircraft records.

9. The preflight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant

sections of the operating documents.

10. The operator must follow the s UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.11. The operator must carry out its maintenance, inspections, and record keeping requirements, in acco rdance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must

be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the

s UAS to service.

12. Each sUAS operated under this exemption must comply with all manufacturer Safety Bulletins.

13. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

14. The PIC must possess at least a sport pilot certificate and a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government

. 15. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the

s UAS in a manner consistent with how the s UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriat e distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). T raining operations may only be conducted during dedicated training sessions. During training, profi ciency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the s UA S with appropriate distance from nonparticipants in

accordance with 14 C.F.R. § 91.119.

16. s UAS operations m ay not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of ope rations. Flights under special visual flight rules (SVFR) are not authorized.

17. The s UA S may not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished aeronautical chart unless a letter of agreement

with that airp ort’s management is obtained, and the operation is conducted in

accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

18. The s UA S may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

19. If the s UA S loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be

recovered in accordance with the operating documents.

20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies

in accordance with the operating documents.21. The PIC is prohibited f rom beginning a flight unless (considering wind and

forecast weather conditions) there is enough available power for the sUAS to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the ma nufacturer if greater.

22. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Noti ce to
Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and pote ntial transponder requirements.

23. The s UA S must remain clear and yield the right of way to all manned aviation operations and activities at all times.

24. Flight operations must be conducted at least 500 feet from all nonparticipating

person s (persons other than t he PIC, V O, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The
operator must en sure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the s UA S , flight operations must cease immediately and/or ; b. The aircraft is operated near ve ssels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an

und ue hazard, and ;

c. Operations nearer to the PIC, V O, operator trainees or essential persons do

not present an undue hazard to those persons per § 91.11 9(a).

25. All operations shall be conducted over private or controlled access property with permission from the land owner/controlle r or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each fli ght to be conducted.

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’ s UAS Integration Office (AFS80) within 24 hours.

Acc idents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

**Make and Model of the Aircraft for Proposed Operations:**

**Make Model** 

DJI Phantom 3 Professional

DJI Inspire 1 Pro / Raw

3D Robotics Solo

3D Robotics X8+**Conclusion:** The opera tion of Robert Hannau using a s UAS, weighing less than 55 lbs., conducted under the proposed restrictions outlined above, will provide an equivalent level of safety supporting the exemptions requested herein. If I can be of any assistance to further expedite this petition, please do not hesitate to contact me at (305) 609

- 4974 or via email bob.hannau@gmail.com

Sincerely,

Robert Hannau

813 NE 97 th Street
Miami Shores, FL 33138

m: 305

- 609

- 4974 e: bob.hannau@gmail.com