January 6'', 2016

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave Washington, DC 20590

Re: Request for exemption underSection 333 ofthe FHA Modernization and Reform Act of2012 and Part 11 ofthe Federal Aviation Regulation.

Name and Address ofthe Petitioner: Jacob Gould 28 Buckingham Place Saint Charles, MO 63301 314-402-0736 Jacob.gould@outlook.com

Dear Sir or Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, Jacob Gould, the Petitioner, request exemption from the following Federal Aviation Regulations in orderto legally operate an Unmanned Aircraft System (UAS) in the NationalAirspace System.

Regulations from which the exemption is requested: 14 CFR 21h 14 CFR 45.23 (B) 14 CFR 61.113 (A) 7 (b) 14CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14CFR 91.103 (b) 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) 14CFR 91.409 (a)(1) 

### & (2) 14 CFR 91.417 (a) 

### & (b) 14 CFR Title 14 Chapter 1 Sub D Part 60 thru 67-61.1to 61.429

The Petitioner wishes to be granted the exemption for use ofthe UAS ofcommercial operations list below.

Application and Operations:Land Surveying and Mapping Aerial Photography Surveying ofStatus of Land Development Projects Crop and Pasture Assessments Real Estate Photography Exterior Photographs and videos Equipment Inspections Visual Monitoring of Equipment

The Petitioner believes the use ofthe UAS's is more economical and saferto 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 UAS to be used is the DJI Phantom 3 Professional. This UAS features as quad rotor, unmanned aircraft and handheld ground control station. The DJI Phantom 3 Professional has a max gross weight of approximately 2.8 pounds, diameter (rotorspan) 23.75 inches, width of 12.5 inches, and height of8.1 inches. The DJI Phantom 3 Professional is equipped with four rotors driven by a lithium battery with electric motors.

Here is an overview ofthe proposed aircraft specifications. Additional design and operational specifications are contained in the DJI Phantom 3 Operating Manual (Attachment A).

Weight (including battery and propellers) Diagonal size {including propellers) Max Ascent Speed Max DescentSpeed Hover Accuracy Max Speed 1280g 590mm 5 m/s 3 m/s Vertical:+/- 0.1 m (when Vision Positioning is active) 16 m/s (Ani mode, no wind)

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 maytechnically applytothe operation of UAS's.

14CFR 21 H: Airworthiness Certificates Certification Procedures for Products and Parts Equivalent Level ofSafety It had been determined that similar UAS's do not require an airworthiness certificate.

14CFR 45.23 (b): Marking ofthe Aircraft 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 near the entrance to the cabin, cockpit, or pilotstation. Equivalent Level ofSafety Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will not have an entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two inch letteringwill be impossible.14CFR 61.113 (A) 7 (b): Private Pilot Privileges and Limitations The regulations provides that no person may serve as a required pilotflight crewmember ofa civil aircraft ofthe United States, unless that person: (1) has a pilot certificate orspecial purpose authorization issued underthis part in that person's physical possession or readily accessible. (2) The flight is only incidentalto that business oremployment. (3) The aircraft does not carry passengers or property for compensation or hire. Equivalent Level ofSafety The Petitionerwill follow all manufacture's' training program and safety manual. I also believe these requirements are unnecessaryto pilot controlled droneflights. Additionally, current FAA proposals have omitted this as afuture requirement forsmall UAS's.

14CFR 91.7 (a): Civil AircraftAirworthiness Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy condition. Equivalent Level ofSafety It has been determinedthat similar UAS's do not require an airworthiness certificate, howeverthe petitionerwill ensure airworthiness through the combined use ofthe manufacture's Operations Manual and preflight checks.

14CFR 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. Equivalent Level ofSafety The equivalent level ofsafety will be maintained by keeping the manufactures Operations Manual atthe ground control pointwhere the pilotflying the UAS will have immediate access to it.

14CFR 91.103 (b): Preflight Instruction This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. Equivalent Level ofSafety As FAA approved rotorcraftflight manuals will not be provided forthe aircraft and exemption will be needed. The Petitionerwill take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance date before initiation offlight.

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, orstructure. Since the aircraftwill be operating at a maximum of 400 feet AGL, we cannot comply with this requirement. Equivalent Level ofSafety The use of UAS will be flown no higherthan 400 feet AGL over developed and developing residential
areas that may be considered congested areas. That will notalways be the case when providing a "Property Survey" flight because they could be conducted over empty lots oracreages with no structures. In the case offlying over or near existing private propertywhile providing aerial imagery, property inspections, or property assessments, landowners will be notified in person by the Petitioner,
oracard left behind bythe Petitioner if requested. The Petitionerwill review with the landowners of associated risks to people and property. Due to the small size ofthe UAS the associated risk to persons, vessels, vehicles and structures in notcomparable 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 orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating below 18,000feet MSL. Equivalent Level ofSafety Most UAS do not have a barometric altimeter. Itdoes have a GPS that will calculate altitude. The Petitionerwill limitflights to a maximum altitude of400 feet AGL.

14CFR 90.151 (a): Fuel Requirements for Flight in VFR Conditions Fuel requirements for flight in VFR conditions: (a) No person may begin aflight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed. (1) Duringthe day, tofly afterthat to at least 30 minutes. Equivalent Level ofSafety The UAS provides battery monitoring, and a low batterywarning to indicate when you should return the UAS to the launch point. The Petitionerwill not initiate aflight unless (considering wind and forecast weather conditions) there is enough powertofly an normal cruising speed to the intended landing point and all flights will be conducted during daylight hours.

14CFR 61.203 (a) 

### & (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows: No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate. No person may operate acivil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section oraspecial flight authorization issued under 19.715 is displayed atthe cabin
orcockpit entrance so that it is legible to passengers or crew. Equivalent Level ofSafety The UAS registration numberwill be properly displayed following the new rules set in place on December 21", 2015. The UAS will also be properly registered on thewebsite. Since no airworthiness certification will be issued for UAS's it is impossible to followthe above requirements.

14CFR 91.405 (a): Maintenance Inspections Each owneroroperator ofan aircraft- (a) shall have that aircraft inspected as prescribed in Subpart Eof the part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 ofthis chapter. Equivalent Level ofSafety The Petitioner shall inspect the aircraft priorto every flight. The Petitioner also will follow the manufacturer's recommended preflight checklist and make any repair necessary before flights occur. The Petitionerwill also maintain a log ofany maintenance or repairs performed.

14CFR 91.407 (a) (1): Maintenance Operation after maintenance, preventative maintenance, rebuilding oralteration: (a) No person may operate any aircraftthat has 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 ofthe chapter. Equivalent Level ofSafetyThe Petitionerwho has the responsibility for the operation and safety ofthe UAS will follow the manufactures suggested replacement parts.

14CFR 91.409 (a)(1) 

### & (2): Inspections Inspections: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, withinthe 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 by43.7 of this chapter; or (2) An inspection forthe 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. Equivalent Level ofSafety The Petitionerwill follow manufacturer's suggestions to ensure thatthe UAS is in condition safe for flight at all times.

14CFR 91.417 (a) & (b): Maintenance Records Except forwork performed in accordance with 91.411 and 91.413 each registered owneroroperator shall keep the following records (1)(i)(ii)(iii) (2)(i)(ii)(iii)(iv)(v)(vi) forthe periods specified in paragraph (b) ofthis section: (1) (2) (3) Equivalent Level ofSafety The Petitionerwill keep a record ofall repairs and modifications. The Petitioneralso proclaims to use approved manufactured parts forall repairs and modifications.

14CFR Title 14Chapter 1 Subchapter D Parts 60 thru 67- 61.1 to 61.429: PilotCertification This section pertains toflight rules, pilot certificate requirements, manuals, etc. Equivalent Level ofSafety The Petitioner believes thatthese requirements are unnecessaryfor pilotcontrolled droneflights and current FAA proposals have omitted his as afuture requirement forsmall UAS's.

In Conclusion: I, Jacob Gould, the Petitioner request exemption from the above mentioned Federal Aviation Regulations in orderto legally operate an Unmanned Aircraft System (UAS) in the National Airspace System in orderto perform Applications and Operations pertaining to my Real Estate and Farming work in a safe and controlled environment.
Sincerely,

Jacob Gould 28 Buckingham Place Saint Charles, MO 63301 314-402-0736