Date: January 13, 2016

U. S

. Department ofTransportation Docket Management System 1200 New JerseyAve., S E Washington , DC 20590
John Condreay, Owner John Condreay Photography 100 Marble Arch Way Lafayette, IN 47905
-7622 765
-449
-4866
RE: Petition ofJohn Condreay Photographyfor Exemption Pursuant to Section 333, ofthe FAA Reform Act
Attn: To whom it may concern

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, John Condreay Photography, operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photography and videography, hereby applies for
an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.1

John Condreay Photography has been in business since 1987 and Sam Crimm II is a license commercial pilotwith over 5300 hours, a pilot for45 years. In recent historywe have been bidding onjobs that have been bid by drone operators in our area and we find it difficult to compete with them. Therefore, we would like to add drone aircraft to ourfeet. Additionally we have a long history of radio control aircraft operation. All of our drone operators will be ratedpilots. As described more fully below, the requested exemption would permit the operation of

small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1. limited 2. predetermined and 3. controlled. The proposed exemption, ifgranted, would allow John Condreay Photography to conduct commercial operations ofsmall, unmanned aircraft systems ("UAS") meeting or exceeding all ofthe operational and safety requirements Congress has set forth in Section 333.

John Condreay Photography is a media/technology company that plans to exploit the capabilities of Unmanned Aerial Systems to offer a multitude ofservices, including:

-Aerial surveying

-Remote sensing

-Agricultural support

-Real Estate Photography

-Aerial film making and photography

-Construction site inspections and monitoring

-Wildlife and forestry monitoring

-Educational and research operations StatutoryAuthority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization ofsafe civil UAS operations in the NAS. Section 333(a) states that the FAA "shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe (comprehensive) plan and rule making required by section 332(b)(1) ofthis Act orthe guidance required by section 334 ofthis Act." In Section 332(b)(1 ), Congress made it clearthat Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:Regulations from which the exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14C.F.R. (91.401
-91.417)
Unmanned Aircraft System, sUAVs are oftentimes seen as superiorto helicopters due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety. We are petitioning for exemption to enable John Condreay Photography to operate a Yuneeq Q500 equipped with a three
-axis gimbals and using High
-Defcameras. This sUAV has a built
-in capability to limit the height itflies above the ground, to limit the radius ofthe distance it flies from the operator and to exclude it from Class 8, C and D airspace including a no-fly zone feature. The Q500 also has the fail safe function ofthe Naza
-M autopilot system which
means when the communication between the Main Controller and the transmitter is disconnected, the outputs of all command sticks from controllerwill go to the center position. If the GPS signal is good enough, the system will automatically trigger Return to Home and will land safely.

The above specifications meet with the Model Aircraft Operating Standards as set below:John Condreay Photographywill only operate its sUAS in line of sight ofa pilot and/or

observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the FOPM. Such operations will insure that the sUAS will "not create a hazard to users ofthe national airspace system orthe public."
When flying sUAV within 5 miles of an airport, airport operators will be notified and the operatorwill give the right ofway to avoid flying in the proximity offull
-scale aircraft.
Maximum flight time for each operational flightwill be 20 minutes. Flights will be terminated at 25% battery power reserve should that occur priorto the 20 minute limit.
The sUAV will be programmed so that itwill not be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.
Minimum crewfor each operation will consist ofthe sUAS Pilot, and Visual Observer.

The sUAS operated bythe petitionerweighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal)

. The sUAV will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally

. Given the small size ofthe sUAS and the restricted sterile environmentwithin which theywill operate, our sUAS operations adhere to the Reform Act's safety requirements.
The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time ofonly 20 minutes, this is offers little or no risk to national security.
Low level oblique photos and video from several angles are far more effective than ground based imageryfor displaying the characteristics of large, complex properties with several buildings and large trees. The applicants in the past have chartered 2
-seat full
-sized helicopters forthis purpose, which has proven more costly than many potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UAwill be valuable to and benefit many buyers and sellers of real property.Additionally, we request that we be allowed to use our system to benefit first responders

nearbywho might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so. (a) No flight will be made with a Gross weight exceeding 55 pounds; (b) AII operations must occur in FAA Class G airspace at no more than 400 ftAGL, at an airspeed of no more than 25 knots and no furtherthan 1/8th NM from the PIC; (c) AII operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; (d) Operations will be restricted to flights over private propertywith the permission ofthe property owner; (e) All required permits will be obtained from state and local government prior to operation; (f) John Condreay Photography, will not be operate over densely populated areas; (g) John Condreay Photography, will not be operating over any open-air assembly of people; (h) John Condreay Photography, will not be operating over heavily tracked roads; (i) John Condreay Photography, will not be operating within 5 NM of an airport or heliport without prior permission. We respectfully request exemption under Section 333 to enable John Condreay Photography, to operate efficient, limited, low
-risk commercial sUAV operations forthe activities stated respecting at all times the space and privacy of citizens and property whilst keeping our skies safe. Sincerely,

John Condreay John Condreay Photography

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

John Condreay Photography requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofthe sUAV System:14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures forthe issuance ofan airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued forthe Yuneeq Q500 under either or both ofthe following provisions:
21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraftwill not carry persons or property, will not carryfuel, and will only fly under strict operational requirements. Combined with the UA's lightweight, being constructed primarily of carbon fiber and plastic, we propose that the UAwill be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is not appropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H. and the requirement foran airworthiness certificate in general. citing the equivalent level of safety outlined in the previous paragraph.
14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it bythe FAA. We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" in the placard on the top ofthe aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity ofthe aircraftwhile it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrastflag or bannerthat contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high orgreater. Since the aircraftwill operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point oforigin.
14 CFR 61.113 Private pilot privileges and ll,Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilot inCommand of an aircraftfor compensation or hire. Subparagraph (b) allows a private pilot to act

as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or propertyfor compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent ofthis application is to conduct a business.
14 CFR 91.7 Prohibits the Operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.
14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 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 aircrewwhile 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 during flight operations. To obtain an equivalent level ofsafety and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.
14 CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flight tests The regulation states that "No person may operate a civil aircraft that is being used forflight instruction unless that aircraft has fully functioning dual controls." The sUAS System ground based control station consists of a small hand
-held radio transmitter and while it does not offer a second set of"controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands
-on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

91.119 Minimum safe altitudes: General. 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 typical mission ofthe sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closerthan 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre-planned has been performed. The aircraftwill be operated at a low altitude allowing, if a power unitfails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising

altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below 400 feetAGL and will not need to maintain cruising altitudes in orderto prevent conflictwith other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computerto the d1splay screen held by the PIC, providing a constantly updated AGL readout.
14 CFR 91.151 Fuel requirements forflight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day
-VFR conditions unless there is enough fuel to flyto the first point of intended landing and to fly after thatfor at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delays to landing. The sUAV is battery operated and the maximum duration offlight from a single battery charge is 18 minutes with a 20% reserve. Since the aircraft will neverfly more than 1/8 NM from the point of intended landing, a full battery charge at launch will ensure thatwe meet the reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and askfor an equivalent interpretation with the word "energy".
14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 5.3 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level ofsafety and meet the intent of 91.203, we propose that documents deemed appropriate forthis aircraft by the FAAwill be collocated with the crew at the ground control station and available for inspection upon request. In orderto identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401
-91.417)
-Maintenance, Preventive Maintenance, 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 require that the aircraft be "approved for return to service by a person authorized under43. 7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor return to service." The PIC will ensure that the aircraft is in an airworthy condition priorto everyflight and in addition conduct detailed inspections after every two hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed by the manufacturer ortheir designated repairfacility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety.Safety and Benefits ofthe UAS

John Condreay Photographywill be using the UAS in a variety of applications that generally require expensive full
-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad benefits overthe use offull
-sized manned aircraftfor electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few

. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin ofsafetyforthe pilots and crew. By granting John Condreay Photography's requested exemptions, the FAAwill help drive development ofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations. John Condreay Photography is committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition.
Conclusion As pointed out in this application, all the SUAs which our companywould use, under authorization by the US DOT
-FAA, are small, light
-weight devices operated within the line of sight ofthe Pilot
-in
-Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location with aviation activities, unless the airtraffic control authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance. All our SUAs have proven capability for controlled flight. They are devices offered forgeneral sale on the market around the world and have of ten been used as Model Aircraft in the USA. We a re certain that the studies conducted until now by the FAA, about Section 332, Public Law 112
-95, 2014, have already provided you with the assurances on the airworthiness of SUAs such as ours.

Forthe foregoing reasons, the exemptions requested herein should be granted and John Condreay Photography should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate bythe FAA. The submission ofthis application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some SUAs may be used for legitimate commercial activities and under reasonably safe conditions.