### U

.S

. Department ofTransportation Docket Management System 1200 New JerseyAvenue SE Washington, DC 20590 February 16, 2016

Requestfor Exemption under Section 333 ofthe FAA Modernization and Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations

. Name and Address ofPetitioner: Trent Strobel 103Windham Circle Hendersonville, TN 37075 615-574-8475 (Cell) Trentstrobel @me.com (Email)
Dear Sir orMadam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, TrentStrobel, the Petitioner, request exemption from the following Federal Aviation Regulations in orderto legally operate an Unmanned Aircraft System (UAS) in the National Airspace System. Regulations from which the exemption is requested: 14CFR21 H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & 

### (b) 14 CFR 91.7 (a) 14 CFR 91

.9 (b)(2) 14 CFR 91.103 (b) 14 CFR 91.109 14 CFR 91.119 14 CFR 91

. 121 14 CFR 91.151 (a) 14 CFR 91

.203 (a) & 

### (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91

.409 (a) & 

### (b) 14 CFR 91.417 (a) & 

### (b) 14 CFR Title 14 Chapter 1 Sub DPart 60 thru 67- 61.1 to 61.429
The Petitioner wishes to be granted the exemption for use of the UAS ofcommercial operations list below

.

### Applications and Operations:



## • • 

### • 

## • • • 

## • • Construction Inspection, Management & 

### Monitoring Property & 

### Equipment Inspection Environmental Assessment Land Surveying& 

### Topography Real Estate Advertising Aerial Photography & 

### Cinematography Agriculture Observation & 

### Monitoring Thermal Environmental Monitoring The Petitioner believes the use ofthe VAS's is more economical and safer to use for the aforementioned purposes. Use ofthe UAS rather than a manned aircraft is more economical to the consumer, and beneficial to the general public due to its small size, low noise and minimal potential for accident Characteristics ofthe Aircraft: The UASs to be used are the 3DR SOLO and OJI Phantom 3 Professional, both of which have wingspans ofless than 24 inches (motor to motor) and ultra-light payload capacities (less than l

.llbs.)

. Being such compact and portable systems, these platforms are ideal for precision aerial mapping missions thanks to the onboard computers, GPS systems, and the related flight management software (Mission Planner). This equipmentallows the operator to safely and efficiently plan and execute missions, and then monitor them in real-time to insure safety. The onboard camera takes and collects high definition still images and video, which is later used to generateartwork, maps, and 30 models ofthe surveyed area. l. Very 

### LightWeight The Phantom 3 Pro weighs 2

.8 pounds and the SOLO comes in at 3.3 pounds with the batteries, propellers, and cameras attached. They are light enough to be hand launched and can gentlyland on almost any surface without use ofa parachute or landing net Its low impact energy (in thecase ofa controlled emergencylanding) significantly reduces the risk ofhazardous situations.
2. Electric Powered The 3DR SOLO & 

### OJI Phantom 3 Pro are both electric powered and operate using brushless technology, making them powerful but quiet and reliable

. The lack ofnoise and zero emission power sources greatly reduce the impact these two unmanned aerial systems have on the environment, especially when compared to conventional manned aircraft
3. Semi-Automatic Flight These two crafts have powerful onboard computers and GPS systems,which monitor the parameters related to 

### maintaining safe & 

### stable flight. This allows thecoordination and carrying out ofhighly technical and pn•cisemissions with minimal input from the operator. Requiring minimal input allows the pilot to focus on the task at hand and monitor the mission as it takes place. Additionally, should it become necessary, the pilot has several options and can tell the UAS to "Go Home," "Land," "Hold," or "Resume" the mission.


### 4. Option for Manual Control While monitoring the flight path ofthe Phantom 3 Pro or SOLO, the operator can override the autopilot at any time. With the flip ofa switch (on the Phantom 3 Pro's remote controller) or push ofa button (on the SOLO's remote controller), automated operations are halted, allowing the aircraft to be flown manually should it become necessary to respond to emergent circumstances.


### Request for Exemption, Section 333 

### ofthe FAA Reform Act pertaining to Federal Aviation Regulations: The Petitioner requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of UAS's.
14

### CFR 21 H: Airworthiness Certificates Certillcation Procedures for Products and Parts 

### Reason for Exception It has been determined that similar UAS's do not require an airworthiness certificate as granted in Exemption No

. 11623, 11650, 11664 and 11734.
14

### CFR 45.23 

### (b}: Marking ofthe Aircraft These regul ations provide that each aircraft must display "N" and the aircraft's regi stration number in letters at least 3 inches high

. Additionally, the aircraft must display the word " EXPERIMENTAL" in letters at least 2 inches high near the entran ce to the cabin, cockpit, or pilot station. 

### Reason for Exception Even though the UAS will have no airworthiness certificate, an exemption may be necessary as the UAS will have not entrance to the cabin, cockpit or pilot station on which the work " EXPERIMENTAL" can be placed

. Given the size ofthe UAS, two-inch lettering will be impossible. The word " EXPERIMENTAL" will be placed on the fuselage i n compliance with 45 .29 (f). The FAA has issued the following exemptions to this regulation to Exemptions Nos

. 10700, 8738, 10167 and 10167 A

. 

### 14

### CFR 61.113 

### (A) 7 {b): Private Pilot Privileges and Limitations The regulatiOn provi d es that no person may 

### ser ve as a required pilot flight crewmember ofa civil aircraft ofthe United States. unl ess that perso n : ( 1) has a pilot ce rtifi cate or specia l purpose authorization iss ued under thi s part in that person ' s physi cal possession or readily accessi ble. (2) The flight 1s only incidental to that business or employment. (3) The aircraft does not carry passengers or property for compensation or hire

.Reason for Exception The Petitioner will follow all manufacturers' training programs and safety manuals. Additionally, current FAA proposals have omitted this as a future requirement for small UAS's.


### 14 CFR 91.7 (a): 

### Civil AircraftAirworthiness Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless itis in an airworthy condition. 

### Reason for Exception It has been determined that similar UAS's do not require an airworthiness certificate, however the petitioner will ensure airworthiness through the combined use ofthe manufacture's operations manual and preflight checks

. 

### 14 CFR 91.9 (b) (2): 

### Civil Aircraft Flight Manual in theAircraft This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent ofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation; the documentation would not be available to the crew. 

### Reason for Exception The equivalentlevel ofsafety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. The FSS has issued the following exemptions to this regulation: Exemption #8607, 8737, 8738, 9299, 9299A to list a few.


### 14CFR 91.103 (b): 

### Preflight Instruction This regulation requires each pilot in commend to take certain actions before flight to insure the safety offlight. AS FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The petitioner will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight.


### 14CFR91.109: Flight Instruction The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." 

### Reason for Exception UAS's and remotely piloted aircraft, by their design so not have fully functional dual controls

. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications

. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft (See exemption Nos

. 5778 K

### & 9862 A). The equivalentlevel ofsafety provided by the fact that neither a pilot nor passenger will be carried in the aircraft and by the size and speed ofthe aircraft.

### 14CFR 91.119: Minimum Safe Altitudes The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of400 feet AGL, we cannot comply with this requirement 

### Reason for Exception The use ofUAS will be flown no higher than 400 feet AGL in LOS over developed and developing residential areas that may be considered congested areas. That will not always be the case when providing a 'Property Survey' flight because they could be conducted over empty lots or acreages with no structures. In the case offlying over ornear existing private property while providing aerial imagery, property inspections, and property assessments, landowners will be notified in person by the Petitioner, orby a card left behind by the Petitioner ifrequested. The Petitioner will review with the landowners ofassociated risks to people and property. Due to the small size ofthe UAS the associated risk to persons, vessels, vehicles and structures is not comparable to manned aircraft and should be taken into consideration.


### 14CFR 91.121 : Altimeter Settings This section requires that each person operating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeter that is set, when operating below 18,000 feet MSL

. 

### Reason for Exception Most UAS do not have a barometric altimeter. Ifdoes have a GPS that will calculate altitude. The Petitioner will limit flights to a maximum altitude of400 feet AGL as granted in Exemption No. 11623, 11664, and 11734.


### 14CFR 90.151 (a) Fuel Requirements for Flightin VFR Conditions Fuel requirements for flight in VFR conditions: (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first po\nt ofintended landing and, assuming normal cruising speed. (1) During the day, to fly after that for at least 30 minutes

. 

### Reason forException The UAS provides a low battery warning to indicate when you should return the UAS to the launch point In addition, a "low" and "critical" battery level warnings and implemented a "Return to Home" action in these situations

. The Petitioner will not initiate a night unless batteries are fully charged, and will make sureto reserve 25% ofthe battery life for returning home, giving plenty oftime to get back to the landing point.

### 14CFR 91.203 (a) & 

### (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows :

• No person may operate a civil aircraft unless ithas an appropriate and current airworthiness certificate

. • No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under 19.715 is displayed at the cabin orcockpit entrance so that it is legible to passengers orcrew
. 

### Reason for Exception To obtain an equivalent level ofsafety and meet the intent of91.203, documentation will be housed at a ground control point where the pilot is flying the UAS for immediate access to the extent they are applicable to the VAS's. In doing some research the FAA has issued numerous exemptions to this regulation

. 

### 14 CFR 91.405 (a): Maintenance Inspections Each owner oroperator ofan aircraft- (a) shall have that aircraft inspected as prescribed in Subpartofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section. have discrepancies repaired as prescribed in part 43 ofthis chapter. 

### Reason for Exception The Petitioner shall inspect the aircraft prior to every flight The Petitioner also will follow the manufacturer's recommended preflight checklist and make any repair necessarybefore flights occur. The Petitioner will also maintain a log ofany maintenance or repairs performed.


### 14 CFR 91
.407 {a) {1): Maintenance Operation after maintenance, preventative maintenance, rebuilding or alteration: (a) No person may operate any aircraft thathas under gone maintenance, preventative maintenance, rebuilding. or alteration unless (1) it has been approved for return to service by a person authorized under 43.7 ofthis chapter. 

### Reason for Exception The Petitioner who has the responsibility for the operation and safety ofthe UAS will follow the manufactures suggested replacement parts.


### 14FR 91.409 (a)O) & (2) : 

### Inspections Inspections: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) an annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. No inspection performed under paragraph (b) ofthis section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an "annual" inspection in the required maintenance records.

### Reason for Exception The Petitionerwill follow manufacturer's suggestions to ensure that the UAS is in a condition for safe flight at all times.


### 14CFR 91.417 (a) & (b): 

### Maintenance Records Except for work performed in accordance with 

### 91.411 and 

### 91.413 each registered owner or operator shall keep the following records (l)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v)(vi) for the periods specified in paragraph (b) ofthis section: (1) 

### (2) (3) Reason for Exception The Petitioner will keep a record ofall repairs and modifications. The Petitioner also proclaims to use approved manufactured parts for all repairs and modifications

. 

### 14CFR Title 14Chapter 1 Subchapter D Parts 60 thru 67-61.1 to 61

.429: Pilot Certification This section pertains to flight rules, pilotcertificate requirements, manuals, etc. 

### Reason for Exception The Petitioner believes that these requirements are unnecessary for pilot controlled drone flights and current FSS proposals have omitted this as a future requirement for small UAS's.


### In Conclusion: I, Trent Strobel, the Petitioner request for exemption from the above mentioned Federal Aviation Regulations in order to legally operate an Unmanned Aircraft System (UAS) in the National Airspace System in order to perform the Applications and Operations listed above in a safe and controlled environment. The Petitioner hopes for a timely consideration as I have made a considerable investment in time and finances on this project.

Trent

### S robel 

### 103 Windham Circle Hendersonville, TN 

### 37075 (615)-574-8475 (Cell) trentstrobel@me.com (E-mail)