September 20 , 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of

the Federal Av iation Regulations from: 14 CFR 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.405(a); 91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) and (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Caleb Gr abendike , an operator of Small Unmanned Aircraft for aerial image acquisition including but not limited to, the following industries: video, still photography , real estate, short range inspection, mapping & surve y, agriculture, hereby applies for an exempt ion from t he Federal Aviation Regulations to allow commercial operation of its small unmanned aircraft

.

Caleb Grabendike 's requested exemption would permit the operation of small

unmanned aircraft under controlled and secure conditions that is: (i) limite d, (ii) predetermined, (iii) subject to controlled access, and (iv) provide greater safety in connection with aircraft operations. As established by the exemptions already granted by the FAA, approval of Caleb Grabendike 's exemption would enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such a ircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

Caleb Grabendike

Phone: 262

- 422

- 5444

Email: Calebgrab@yahoo.com

Address: 2927 Ridley Rd. Hartland, WI 53029

Regulations from which the exemption is requested: 14 CFR 61.113(a) and (b)

14 C.F.R. 91.103

14 C.F. R. 91.119

14 C.F.R. 9 1.121 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) and (b)S mall unmanned aircraft operated by Caleb Grabendike weigh less than 55 pounds,

including the payload (i.e. camera, lens, and gimbal). They operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally.

Caleb Grabendike will only operate its small unmanned ai rcraft in line of sight and will

oper ate only within the secure area described in the FOPM. Such operations will insure

that the small unmanned aircraft will “not create a hazard to users of the national airspace system or the public.”

Given the small siz e of Caleb Grabendike 's small unmanned aircraft and the restricted secure environment within which they will operate, Caleb Grabendike 's small unmanned

aircraft operations adhere to the Reform Act’s safety requirements. Additionally, due to

the size of the small unmanned aircraft , permission from relevant property owners or other applicable parties, and the limited areas in which they will operate, approval of th is application presents no national security issues. Based on the substantial level of safety surrounding the proposed operations, and the significant public benefit (enhanced safety), reduction in environmental impacts (reduced emissions and noise), the g rant of the requested exemption is in the public interest. Accordingly, Caleb Grabendike respectfully requests that the FAA grant the requested exemption.

Aircraft And Equivalent Level Of Safety

The operating limitations proposed by Caleb Grabendike prov ide for at least an equivalent or higher level of safety because operations further enhance safety of aerial image collection using conventional aircraft.

The limitations and conditions include:

• The small unmanned aircraft will weigh less than 55 pound s. Typically under 6 pounds.

• Flights will be operated within line of sight of a pilot and/or observer.

• Maximum flight time for each operational flight will be no more than 30 minutes. Flights will be terminated at no less than 25% battery power res erve should that occur prior to

the 30 minute limit.

• Flights will be operated at an altit ude below 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of th e small unmanned aircraft Pilot and

the Visual Observer

.• The small unmanned aircraft will only operate within a confined secure area as defined

in the FOPM.

• A briefing will be conducted for planned small unmanned aircraft operations prior to each day’s flight. All personnel performing duties within the boundaries of the safety perimeter are required to attend.

• The operator will obtain consent of all persons involved in the filming and ensure that only consenting person s will be allowed within 500 feet of the flight operation.

• The Pilot and observer must be trained in small unmanned aircraft operations and have received current information on the particular small unmanned aircraft to be operated as required by the FOP M.

• The Observer and pilot will be able to communicate by voice at all times.

• Written and/or oral permission from the relevant property holders will be obtained prior to flight operations.

• All appropriate permissions and permits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

• If the small unmanned aircraft loses communications or loses its GPS signal, the small

unmanned aircraft will ha ve the capability to return to a pre

- determined location within the secure perimeter and land.

• The small unmanned aircraft will have the capabili ty to abort a flight in case of unpredicted obstacles or emergencies.

14 C.F.R. §91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(c) O ver other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.”

Because Cal eb Grabendike requests authority to operate at altitudes no higher than 400 AGL, and not more than 200 above an elevated platform from which filming is planned,an exemption is needed to allow such operations. Except for the limited conditions

stated in th e FOPM, the small unmanned aircraft will never operate higher than 400 AGL. It will, however, be operated in a restricted area within a security perimeter, where buildings and people will not be exposed to operat ions without their pre

- obtained

consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the

small unmanned aircraft as well as the location where it is operated. No flight will be taken without the permission of property owners or local officials. Because of the advance notice to the property owners and participants in the filming activity, all affected individuals will be informed of the planned flight operations. Compared to flight operations for manned aircraft and the lack of flammable fuel, any risk assoc iated with the proposed small unmanned aircraft operations is far less than conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the small

unmanned aircraft will ensure separation between a small unmanned aircraft and

conventional aircraft.

14 C.F.R. §91.121: Altimeter Settings

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As a small unmanned aircraft may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level of safety will be achieved by the operator, pursuant to the FOPM and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an ai rcraft operator or owner shall “have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this c hapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Caleb Grabendike operations. Mainten ance will be accomplished by the operator. An equivalent level of safety will be achieved

because the small unmanned aircraft are limited in size, will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical is sues arise,

the small unmanned aircraft can land immediately and will be operating from no higher than 400 feet AGL. As provided in the FOPM, the operator will ensure that the small

unmanned aircraft is in working order prior to flight, perform any require d maintenance, and keep a log of any maintenance performed. Moreover, the operator is the personmost familiar with the small unmanned aircraft and best suited to maintain it in an

airworthy condition.

Summary for Publication

Pursuant to 14 C.F.R. Part 1 1, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Caleb Grabendike seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91. 405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) to operate commercially a small unmanned vehicle (55 pounds or less) in commercial image acquisition operations. As established by the

small unmanned aircraft exemptions already granted by the FAA, allowing commercial operations of small unmanned aircraft in agriculture, real estate, inspection, S & R, and film industries will enhance safety by reducing risk. Conventional survey, agricultural, mapping, inspection, and film operations, using turbine aircraft, operate at low altitudes and present the risks associated with aircraft that weigh around 4,000 pounds, and which carry large amounts of Jet A fuel. Such aircraf t must also fly to and from the target location. In contrast, a small unmanned aircraft weighing fewer than 55 pounds and powered by batteries eliminates virtually all of that risk given the small size and lack

of combustible fuel. The small unmanned aircraft is carried, and not flown, to target site. In this regard, the small unmann ed aircraft carries no passengers or crew and, therefore, will not expose them to the risks associated with manned flights.

The operation of small unmanned aircraft conducted in the strict conditions outlined in the FOPM will provide an equivalent level o f safety supporting the grant of the exemption requested herein. The small unmanned aircraft o perate at slow speeds,

close to the ground, and in a secure environment. As a result, they are far safer than conventional operations conducted with turbine helic opters flying near the ground and people.

Privacy

All flights will occur over private or controlled access areas with the property owner’s prior consent and knowledge. Recognizable images will only be recorded of people who have given their consent or otherwise have agreed to be in the area where active image acquisition will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security) provide more than adequate justification to grant Caleb Grabendike ’s requested exemption, allowing for

Caleb Grabendike 's small unmanned aircraft commercial operations for the listed

industr ies pursuant to the included FOPM.If you have any questions or need any additional information, please contact the

undersigned by phone at 262

- 422

- 5444 or via email at Calebgrab@yahoo.com

.

Sincerely,

Caleb Grabendike

Owner