07/15/2015 11:46 FAX 919 541 0072 USEPA OAQPS ESD



### Docket Operations, M-30 , U.S. Department ofTransportation Docket Management SystenL 1200 NewjerseyAvenue SE Room Wl2··140 

### West Building

### Ground Floor Washington, D.C. 20590 

### Aerial Images and Inspections 44 Blackburn Road New 

### Hill, North Carolina 2756:2
Re: 

### r;;xemption Request for Section 333 ofthe FAA

**f.~eform** 

### Act and Part 11 ofthe Federal Aviation Regulations f:·om 14

### C.F.R. 91.7 (a), 14

### C.F.R. 91.9 

### (b) (2), 1.4 C.F.R. 91.103, 14

### C.F.R 91.119,14 

### C.F.R. 91.121,14 

### C.F.R. 91.405 (a), 14

### C.F.R. 91.407 (a)(l), 14 

### C.F.R 91.4·09 

### (a)(1)&(2), 14 C.F.R. 91.41·;· 

### (a)&(b), 14 C.F.R. §

**L~5.23** 

### (b). 

### To Whorn ft May Concern This 

### application is being submitted on my own behalf. As required by 

### Section 333 

### ofi:he Federal Aviation Administration (FAA) Modernization and Reform Acof2012 

### and 14 

### C.

**F.~.** 

### Part 11, Aerial Images and Inspections 

### (All) applies for an exemption from

**tlv~** 

### above listed federal regulations. All 

### operates small, unmanned aircraft equipped to conductphotography and videography for the real estate industry, engineeringinspectors, landscape gardeners, and site development engineers. If

### this <:xemption is granted, all 

### operationswill be 

### conducted within and under the 

### conditions established by the FAA. This exemption would permit the operation ofsm<d1, unmanned, and relatively inexpensive Unmanned AircraftSystems 

### (UAS) under controlled conditions in airspace that is 1) 

### limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements :o the already safe operations in the real estate and engineering industries presentlyusinglifting devices such as cranes and conver1tional aircraft. Approved ofthis exemption V!ould enhance safetyand fulfill the Secretary ofTransportation's responsibilities t J 

### establish requirements for the safe operation ofsuch aircraft systems in the natio:1al airspace system. The petitioner, Gregory A. Green has been flying remote control aircraft since the mid-1970 

### and has recentlybegan tlying quadcoptcrs, both for recreational purposes and vvith

**thE~** 

### intentofforming Aerial Images and Inspections. He has acquired over 100 

### hours with quadcopters. Granting this 

### petitior would be in the interestofthe public, property on the ground, and the national al

**~space** 

### system. The aircraftto be used is a DJl Phantom 2Vision+ 141002/00707/15/2015 11:47 FAX 919 541 0072 USEPA OAQPS ESD

For additional information, please contact: 

### Owner: Gregory Green Aerial !mages and Inspections 44 Blackburn Road Nevv Hili, North Carolina

**2756:~** 919-S64-67B1 Regulations from which the exemption is requested: 14 C.F.R. 91.7 (a}, 14 C.F.R. 91.9 (bJ(2), 14 C.F.R. 91.103,14 C.F.R. 91.119,14 C.F.R. <:'1.121, 14 C.F.H. 91.405 (a), 14 C.F.R. 91.407 (a)(1), 14C.F.R. 91.409 (a)(1)&(2), 14 C.F.R. 91.417 (a)&(b) Section 333 (a)(c) allows the Secretary ofTranspor:ation to determine the ability of an unmanned aircraft to opera·:e safely in the National Air Space. The Secretary·is directed to deterrnine which UAS are able to operat2 safelywithout posing a threat to persons, property on the grcund, the nation airsr•ace system, orto national security. These determinations will be made based .1pon several factors: The vveight, speed, and operati·Jnal capability are important components ofthe aircraft as welt as whether or notthe aircraftwill

**b;~** operated in close proximity to airports and population centers. All aircraft are quadcoptersWE-ighing five pounds or less withthe camera included. The camera is the only payload ofthese UAS. They c,perate at speeds no greaterthan 30 miles per hour, have the car>ability to hover, and move in the vertical and horizontal plane. They will onlyoperate in line ofsi :e. These very restrictive operations heip ensure the UAS will not create a ha::ard to the public orthe national airspace system. As a result, All aircraft clearlypresent an equivalen': level ofsafety to the NAS as envisioned 

### by Congress. The relativelysmall size ofthe UAS and restrictive operati.onai parameters imposed byAir will result in an improved level ofsafetyto the NAS and the public when compared with traditi)nal methods ofconducting photography and videography :Jt real estate, landscaping, and engineering preparatior1 sites. As a result, All respectively requests the Secretary of Transportation grantourpetition ofexemptions frcm Section 333. Aircraft and Equivalent Level ofSafety The applicant ask.s that'the exemption requested above apply to unmanned civil aircrafts that have the characteristics and operate 'Nith the limitations as described below. These limitations providefor atleast an equivalent or higher level ofsafety to operations under the currentregulatory

**structur~** because the proposed operations represent

### a safety enhancementto the cperations conducted with other equipmentsuch as cranesand conventional aircraft. 141003/00707/15/2015 11:47 FAX 919 541 0072 USEPA OAQPS ESD

The following limitations and conditions to which All agrees to follow when conducting commercial operations under an FAA

**i~;sued** exemption include: L The UAS will weigh less thar: 5 lbs. 2. Flights will be operated witl:in line ofsight ofa pdot and/or observer when necessary. The pilot and obser;erwill be able to co :nmunicate with each other at all times. 

### 3. Maximum total f1ight time for each operational 

### fl ghtwill be 

### 25 minutes. Flights 

### vlill be terminated at 25 percent battery power should that occur prior to the 

### 25 minute limit. 'The battery ofthe UAS represents the fuel ofthe vehicle and provides a 

### much safer and predictable en'!ironmentthan traditional flammable fuels. 4·. Flights 

### will be operated at an altitude ofno more than 200 feet above ground level (AGL). 

### S. Crew 

### for each operation will consist ofthe UAS 

### P Jot. 

### 6. The UAS 

### Pilot will be the Pilot in Command 

### (PIC) 7. The UAS will only operatewithin a confined area 

### B. The operator will obtain the consent ofall persor.s involved in the photography and filming. 9. Pilot and observer will have been trained in oper:ltion ofUAS generally and received up-to-date information on the particular UAS to be used. 10. Written andjor oral

**permi~:sion** from the releva.nt property holders

### will be obtained. 11. Ifthe UAS loses communicc:tions or loses its GP:; signal, the UAS will have capability to return to a pre-determined location and land. This is called the Return to Ground (RTG) capability. 12. Any applicable state rules and regulations will be strictly adhered to at all times. These limitations and conditions satisfy Part 91.10::;, Part91.109, Part 91.1.19 and Part 9:L151.. CF.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. § 91.203 (a) (1) Subpart H, entitled Airworthin1:ss Certificates. Based upon the size ofthe UAS. its limited operating area, and the other limitations 

### and conditions presented above, it is obvious the 

### UAS could operate with an equivalent level ofsafetywithout an airworthiness :ertificate. The FAA Act (49 USC.§ 4470l(f) and Section 333 ofthe Reform Act authorize the FAA to exempt a\rcrafts from the requirement for an airworthines:: certificate, upon consideration ofthe size, weight, speed, operational capability, an

### :l proximity to airports and populated areas ofthe particular UAS. 'fhe UAS to be operated byAll is less than 5 pounds fully loaded, carries neither a pilot nor passenger, carries no explosive materials or fJammabJe liquid fuels, and \Vill operate exclusively within a secured area. Operations underthis exemption will be tightly controlled and monitored by the operator. These safety enhancements 141 004/00707/15/2015 11:47 FAX 919 541 0072 USEPA OAQPS ESD

provide a greater degree of

**saf~ty** to the public and property owners than conventional operations conducted with airworthiness certificates issued under 

### 14 

### C.F.R. Part 21, Subpart 

### H. Application ofthese crite ·ia demonstrates there is no credible threat to national sect:rity posed bythe UAS, due to its size, speed of operation, location ofoperation, lack ofexplosive

**n~**aterials or flammable liquid fuels, an.d inabilityto carry a substantial externallc:1d. 14 C.F.R. § 45.23 (b). Ail respectively requests the FAA Administratorgrant 

### .m exemption from this requirement. 49 US.C §44711: Additionally due to the UAS limikd size and the lack ofa cabin, cockpit, or pilot station, itis impossible to mark thE' aircraftas required by regulation. An exemption is ne(essaryand requested for this requirement. Additionally no person may operate a U.S.-registerrd civil aircraftfor which 

### a flight manual is not required by Section 21.5, unless then· is available in the aircrafta currently approved airplane or Rotorcraftflight manual, approved manual material, markings, and placards, or

### a combination ofthe abcve. Howeverthe

### UAS, given its sizeand configuration has no ability orplace to carry such a flight manual onthe aircraft The equivalentlevel ofsafetywill be maint:tined by keeping the flight manual at the ground control pointwhere the pilot flying the UAS will have imrnediate access to it An exemption is requested f)rthis requirement. 14 CF.R § 91.103: Preflight action: This regulation .nstructs the pilot in command to perform certain preflightactions to insure the safety ofnight, the public, property and the NAS. As an FAA approved flight manual wili not be provided for the aircraft, an exemption will be needed. Followingthe instrucUons in the UAS operating n1anual. will. provide an equivalentlevel ofsafety. Additionally the PIC will take preflightactions by reviewing weatherforecasts, 

### t1i ght battery requirements, landing and takeoffdistances, c:md aircraftperform;:_nce data before initiation of night. 14 CF.R. § 91.109: Flight instn;ction: Section 91.10:3 provides that no person may operate a civil aircraftthatis

**b1~ing** used for flight irstruction unless thataircraft has 

### fully functioning dual controls. Remote control airuaft such as UAS are operated through communications betw:=en the aircraft and;:: remote control transmitter. 

### These transmitters 

### are not builtwith dual control c1pability. As such it is irnpossible to meetthis requirEmentand an exemption is requested. An equivalent level ofsafetyis provided sincE the aircraftdoes not carrypassengers and because ofthe limited size and speed ofthe aircraft. 14 C.F. R. § 91.119: Minimum S<::fe Altitudes Section: 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119(d) onl.v allows helicopters to be operated atiess than the minimums prescribed under certain conditions. Technically the LJAS could be considered to be a he!: copter and an exemption will be needed to operate at altitudes not to exceed 200 feet AGL. 141005/00707/15/2015 11:48 FAX 919 541 0072 USEPA OAQPS ESD

The equivalent level ofsafetywill 

### be achieved give'! the size, weight, and speed of 

### the UAS, as 

### -vvell as the location where it 

### is operateci. No rlight will 

### be taken without thepermission ofthe property owner. Because ofthe advance notice to the property owner 

### and any participants in the activity, all affected individuals wm 

### be aware of the planned flight operations. Compared to tlight O:Jerations with aircraft or rotorcraft\Neighing far more than the maximum 5 :lOunds, and the lack of ftan1mable fuet any risk associated with these

**oper::~tions** is far less than those presently presented with conv2ntional aircraft. In addition, the low-altitude operations ofthe UAS will ensure separation between these small UAS operations and the operations ofconventi:mal aircraftthat must complywitb14 C.F.R. 

### § 91.119. Section 91.121 Altimeter Settings: This regulation requires each person operating an aircraft to maintain

**cruisin~;** altitude by reference to an altimeter. However the U/\S only has 

### a GPS altitude re<:1dout on the remote ;:ontrol box operated bythe pilot. Therefore an exemption is nee.jed. An equivalentlevel ofsafetywill be achieved by the operator maintaining awareness with the GPS .::ltitude in an identical fashion as a pilot would in an aircraftwith an altimeter.
14 C.F.R. 

### § 91.151(a): Fuel Requirements for Flight :n VFR Conditions. Section 9Ll5l(a) prohibits an individual from beginninga tlight in an airplane underVFR conditions unless 

### the aircraft 

### has enough fuel to tly to the point ofintended landing, and, assuming normal cruising speed (1) during the clay, to fly after thatfor atleast 30 minutes; or (2) at night, to fly after thatfor atle; st45 minutes. Since the battery ofthe UAS has enough power for approximately 30 minutes ofl1ight, this requirement is impossible to meet. Under this scenario, the aircraftwould nothave any flight time remaining to

**ac~~omplish** its tasks. VVith the limitations and conditions /\.!1 has alreadyagreed to implement, 

### a !'lighttime based on battery life is reasonable. An exemption from 14 

### C.F.R. § 91.151(a) 

### falls within the scope ofother exemptions. T'he UAS will be operated in a controlled area with only clients present. Since the UAS has only 30 minutes ofbatterylife, the type of !'isks thatSection 91.1S(a) ·1.vas intended to minimize will notbe present, espedally consideringthe size and speed ofthe small aircraft.
An equivalentlevel ofsafety can be achieved by lim ting Jlights to 25 minutes as already agreed or 25 percentofbatterypower, whichever happens first. This 

### limitation ·vvili allow the pilot sufficient time to retu ·n the aircraft to its predetermined landing area. 14 C.FJt §§ 91.203(a) and (b): Carrying Civil AircraFt Certification and Registration. The UAS is a very small aircraft, weighs less than 5 pounds, and consequently, i.s

**f~1r** too small to carryeitherpassengers or crew memtwrs. As such, it is impossible to carry the airworthiness certitlcation and registration documents, orto display them 141006/00707/15/2015 11:48 FAX 919 541 0072 USEPA OAQPS ESD

on the aircraft. An equivalent level ofsafetycan be achieved by maintaining these documents, appropriately, at the airfield with the p lot. 14 C.F.R. §§ 91.405(a); 407(a)(1); 409(a)(2); 41.7(a) and (b): Maintenance Inspections. These regulations require that an aircraft operator or owner shall have thataircraft inspected and shall have discrepancies repaired as prescribed in Part43 ofthis chapter, and others shall inspect ormaintain theaircraft in compliance with Part 43. Since these secti.ons and Part 43 apply only to aircnftwith an airworthiness certificate, these sections should not apply to the applicant The operator will perform ali maintenance required by the flight marual. The manual also recommends the operator verify that the aircraft is in safe operating condition. 

### perform any required maintenance as mentioned before the flight, and to keep 

### a iog ofany maintenance done. The recommendations

## wm be accomplished.An equivalent level 

### ofsafety willl:e furthered because these UAS arevery small and applicant has agreed to**operat~** only in restricted a ·eas, no higher than 200 feet 

### AGL, and for a shortperiod oftime. 

### Ifa mechanical problem should arise, the UAS would land immediately. Applicant be.lieves all ofthe requirements ofSectio 1 333 ofthe Reform Act of 2012 have been rnet and exernption from all parts ofthe Act, as requested, is appropriate. 

### As stipulated above, the

### UAS is very small and can ·:ravel 

### at 30 miles per

### hour at most 'The aircraft will not be operated within**closE~** proximityto airports and densely populated areas, with 

### avisual line ofsight, and will not be a hindrance to the 

### national air space. 

### Your consideration 

### ofthis request is appreciated. Gregory A. Green Aerial Imagery and Inspection; 44 Blackburn Road 

### New Hill, North Carolina 27562 (910' l- '4**6~(31** 

### _. .-·J.)6

-- It

. aerj.aJskyimages@gmail.com 141007/00707/15/2015 11:46 FAX 919 541 0072 USEPA OAQPS ESD

To: July 15, 2015
Docket Operations, M-30 US Department ofTransportation Docket Management System 1200 NewJersey Avenue SE Room W12-140 West Building Ground Floor Washington, D.C 20590
From: Owner: Gregory Green Aeriallmages and Inspections 44 Blackburn Road New Hill, North Carolina 27562 919··564-6781 141001/007