December	24, 2015

U.S.	Department	of	Transportation West	Building	Ground	Floor Room	w12

- 140	1200	New	Jersey	Ave SE	Washington,	DC	20590
Name	and	Address	of	Petitioner: Andre	Siegrist 815	Camp	Meeting	Road East	Earl,	PA	17519 Email: andresiegrist@yahoo.com Phone:	717

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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, Andre	Siegrist,	the	Petitioner,	r equest	exemp tion	from	the	following	Federal Aviation Regulations	in	order	to	legally	operate	an	Unmanned	Aircraft	System	(UAS)	in	the	National Airspace System. **Regulations	from	which	the	exemption	is	requested:** 14CFR	21	H 14	CFR	45.23	(b) 14	CFR	61.113	(A)	7	(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	D	Part	60	thru	67

- 61.1	to	61.429 The	Petitioner	wishes	to	be	granted	the	exemption	for	use	of	the	UAS	of	commercial	operations from	the list below. **Applications	and	Operations:**

 Aerial Video	and Photography

 Land	Surveying	and	Mapping

 Forest Health	Monitoring

 Harvesting	Monitoring

 Topography

 Environmental	Assessment

 Aerial	Photography

- Real	timeEquipment	Inspections

•	Visual	Monitoring	of	Equipment
The	Petitioner	believes	the	use	of	the	UAS's	is	more	economical	and	safer	to	use	for	the aforementioned purposes.	Use	of	the	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	of	the	Aircraft: Full	Description	of	the**  **UAS** The	UAS	to	be	used	is	the DJI	Phantom	3	Standard Manufacturer:	DJI Model	Designation: Standard	version	of	Phantom3	line,	Quad	copter	style	with	4	engines	and
camera. Serial	Number: Class:	Rotorcraft Takeoff	Weight:	2.6808 pounds	or	1216	grams Category:	Both	Land	and	Sea Number	of	Engines:	4 Engine	Type:	Electric powered	by	batteries

**C har** **acteristics	of	the	Phantom	3	Standard** 1. Very	Light	Weight The Phantom	3	Standard is	so	light	the	operator	can	launch	it	by	hand	and	let	it	land	on	almost	any surface	without requiring	a	parachute	or	landing	net.	Its	low	impact	energy	(in	the	case	of	a controlled	emergency landing)	also	significantly	reduces	the	risk	of	hazardous	situations.
2.	Electric

- powered The Phantom	3S	is	electric	po wered	by	batteries	that	power	4	electric	engines. 3.	Autonomous	Flights	and	GPS	Technology The	artificial	intelligence	incorporated	within	the P3S	allowing	for	stable	automatic	take	off,	and landing	with	the	DJI	GO	app.	The	GPS	technology	also	allows	for	stable	movement	and	complete control	of	the	aircraft,	even	if	the	pilot	is	not	moving	the	aircraft,	it	will	stay	in	place	and	stable.	The GPS	se nsors	also	know	the	takeoff	point,	and	one	press	of	a	button	can	return	the	aircraft	to	the starting	point	at	a	safe	altitude,	and	lower	to	the	landing	point	where	the	aircraft	took	off	to	begin the	flight. 4.	Option	for	Manual	control Additionally,	th e P3S provides	an	override	capacity	that	allows	the	operator	to	take	manual	actions during	the	flight	(Go	to	Home,	Go	Land,	Hold	and	Resume	the	mission)	and	also	suspends automated operations	and	take	manual	control	of	the	aircraft	should	it	become necessa ry	to respond	to	emergency	circumstances ,	thanks	to	the	remote	controller	provided	with	the	system.
**Public	Interest	and	Benefits** Providing	the	public	with	commercial	aerial	services	that	are	much	more	economical	are	a	good aspect	of	this	exemption	compared	to	past	methods,	such	as	helicopters	and	airplane	services.	Will be	primarily	filming	video	and	taking	photos	for	Real	Estate,	a nd	scenery	purposes. The	UAS	will pose	no	threat	to	the	public,	given	its	safety	features	and	pilot	experience,	as	well	as	the	lightweight and	lack	of	combustibility	of	the	aircraft.	The	UAS	will	also	benefit	the	environment	due	to	thebattery	power	it	run s	on,	and	the	information	being	provided	by	surveying	and	forest	monitoring,

though	this	excludes	emergencies	such	as	forest	fires	and	other	situations	where	authorities	are nearby. **Safety** Flights	will	be	conducted	within	suggested	parameters	by	the	FAA. Flights	will	be	away	from	highly congested	areas,	cities,	airports,	national	parks,	and	no	fly	zones	(NFZ).	Flights	will	also	be controlled	at	a	suitable	speed,	and	under	400	feet.	Safety	will	be	the	first	priority	with	every	flight by	following	the	guide lines,	staying	away	from	illegal	areas,	and	using	good	judgment to	not	disturb or	harm	anyone.	Inspection	of	the	aircraft	will	take	place	before	each	flight	to	ensure	quality	of	the UAS	and	operating	parts.	Repairs	will	be	made	before	problems	arise	if	parts	become	worn,	or damaged. Request	for	Exemption,	Section	333	of	the	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 Certification	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 E xemption	No.	11623,	11650,	11664	and	11734. 14	CFR	45.23	(b):	Marking	of	the	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	di splay	the	word "EXPERIMENTAL" in	letters at	least	2	inches	high	near	the	entrance	to	the	cabin,	cockpit,	or	pilot	station. Reason	for	Exception Even	though	the	UAS	will	have	no	airworthiness	certificate,	an	exemption	may	be	needed	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	of	the	UAS,	two

- inch	lettering	will	be	impossible. The	word "EXPERIMENTAL" will be	placed	on	the	fuselage	in	compliance	with	45

. 29 (f). The	FAA has	issued	the	following	exemptions	to	this	regulation	to	Exemptions	Nos.	10700,	8738, 10167 and	10167A. 14	CFR	61.113	(A)	7	{b):	Private	Pilot	Privileges	and	Limitations The	regulation	provides	that	no	person	may	serve	as	a	required	pilot	flight	crewmembe r	of	a	civil aircraft of	the	United	States,	unless	that	person:	(1)	has	a	pilot	certificate	or	special	purpose authorization issued	under	this	part	in	that	person's	physical	possession	or	readily	accessible.	(2) The	flight	is	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	program	and	safety	manual. Additionally,	current	FAA	proposals	have omitted	this	as	a	future	requirement	for	small	UAS ' s. 14	CFR	91.7	(a):	Civil	Aircraft	Airworthiness Civil	Aircraft	Airworthiness:	(a)	No	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy condition. Reason	for	Exception It	has	been	determine d	that	similar	UAS's	do	not	require	an	airworthiness	certificate,	however	thePetitioner will	ensure	airworthiness	through	the	combined	use of	the	manufacture's	Operations

Manual and	preflight	checks

. 14	CFR	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	th e	Aircraft 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	of	this	requirement	is	to	ensure	that	flight manual information	is	available	to	the	aircrew	wh ile	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	equivalent	level	of	safety	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.

14 CFR	91.103	(b):	Preflight	Instruction This	regulation	requires	each	pilot	in	commend	to	take	certain	actions	before	flight	to	insure	the safety of	flight.	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	takeoff	distances	and	aircraft	performance	data	before	initiation of	flight.

14	CFR	91

. 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	contr ols.	Flight control	is	accomplished	through	the	use	of	a	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	f light	instruction	in	experimental	aircraft. See	exemption	Nos. 5778K	&	9862A.	The	equivalent	level	of	safety	provided	by	the	fact	that	neither a	pilot	nor	passenger will	be	carried	in	the	aircraft	and	by	the	size	and	speed	of	the	aircraft. 14	CFR	91.119:	M inimum	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	of 400	feet	AGL,	the	reque sts	of	each	regulation	will	be	followed	as	best	as	possible. Reason	for	Exception The	use	of	UAS	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	of	flying	over	or	near	existing	private	property	while	providing	aerial imagery, property	inspections,	and	pr operty	assessments,	landowners	will	be	notified in person	by the Petitioner,	or by	a	card	left	behind	by	the	Petitioner	if	requested.	The	Petitioner	will	review with	the	landowners	of associated	risks	to	people	and	property.	Due	to	the	small	size	of	the	UAS	the associated	risk	to	persons, vessels,	vehicles	and	structures	is	not	comparable	to	manned	aircraft and	should	be	taken	into consideration. 14	CFR	91.121:	Altimeter	SettingsThis	section	requires	that	each	person	operating	an	aircraft	shall	maintain	th e	cruising	altitude	or

flight level	of	that	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.	If	does	have	a	GPS	that	will calculate	altitude.	The Petitioner	will	limit	flights	to	a	maximum	altitude	of	400	feet	AGL	as	granted	in	Exemption	No. 11623, 11664,	and	11734. 14	CFR	90.151	(a)	Fuel	Requirements	for	Flight	in	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	point	of	intended	landing	and,	assuming	normal	cruising	speed.	(1)	During	the day,	to fly	after	that for	at	least	30	minutes. Reason	for	Exception 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	Hom e" (or	"Go land")	action	in	these	situations.	The	Petitioner	will	not	initiate	a	flight	unless	(considering wind	and forecast	weather	conditions)	there	is	enough	power	to	fly	at	normal	cruising	speed	to	the intended landing	point	and	all	flights	will	be	co nducted	during	daylight	hours	and	at	times	not	to	be a	nuisance	to others. 14	CFR	91.203	(a)	&	(b):	Carrying	Civil	Aircraft	Certification	and	Registration This	regulation	provides	as	follows: •	No	person	may	operate	a	civil	aircraft	unless	it	has	an	appro priate	and	current airworthiness certificate. •	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate	required by	paragraph (a)	of	this	section	or	a	special	flight	authorization	issued	under	19.715 is displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or crew. Reason	for	Exception To	obtain	an	equivalent	level	of	safety	and	meet	the	intent	of	91.203,	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	UAS's.	In	doing	some	research	the	FAA	has	issued	numerous	exemptions	to this regulation. 14	CFR	91.405	(a):	Maintenance	Inspections Each	owner	or	operator	of	an	aircraft

- (a)	shal l	have	that	aircraft	ins pected	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	chapter. Reason	for	Exception The	Petitioner	shall	inspect	the	aircraft	prior	to	every	flight.	The	Petitioner	also	will	follow	the
m anufacturer’s recommended	preflight	checklist	and	make	any	repair	necessary	before	flights
occur. The	Petitioner	will	also	maintain	a	log	of	any	maintenan ce	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	that	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	of	this chapter.Reason	for	Exception

The	Petitioner	who	has	the	responsibility	for	the	operation	and	safety	of	the	UAS	will	follow	the manufactures	suggested replacement	parts. 14	FR	91.409	(a){l)	&	(2):	Inspections Inspections:	(a)	Except	as	provided	in	paragraph	(c)	of	this	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	of	this	chapter	and	has	been	approved	for	return	to	service	by	a	person authorized	by	43.7	of this	chapter;	or	(2)	An	inspection	for	the	issuance	of	an	airworthiness certificate	in	accordance	with	part 21	of	this	chapter.	No	inspection	performed	under	paragraph	(b) of	this	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	maintena nce	records. Reason	for	Exception The	Petitioner	will	follow	manufacturer's	suggestions	to	ensure	that	the	UAS	is	in	a	condition	for safe flight	at	all	times. 14	CFR	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) of	this	section:	(	1)	(2)	(3) Reason	for	Exception The	Petitioner	will	keep	a	record	of	all	repairs	and	modifications.	The	Petitioner	also	proclaims	to
use approved	manufactured	parts	for	all	repairs	and	modifications. 14CFR	Title	14	Chapter	1	Subchapter	D	Parts	60	thru	67

- 61.1	to	61.429:	Pilot	Certification This	section	pertains	to	flight	rules,	pilot	certificate	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, Andre	Siegrist,	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	pertaining	to	my aerial	services	such	as aerial	photography,	and	video	among	other	applications	to	benefit	the	public .	The	Petitioner	hopes for	a	timely	consideration to	perform	these	aerial	services	legally. Please	feel	free	to	contact	me	via email	at andresiegrist@yahoo.com or	by	phone	at	717

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Thank	You,

Andre	Siegrist Owner 815	Camp	Meeting	Road East	Earl,	PA	17519 Email: andresiegrist@yahoo.com Phone:	717

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