Robert W. Lacy

2709 Woodshire Dr. Arlington, TX 76016 rlacy@sbcglobal.net

Exemption Request Pursuant to Section 333 of the FA A Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H 14 CFR 45.23(b) 14 CFR 61.113(a) and (b) 14 CFR 91.7(a) 14 CFR 91.9(b) (2)
14 CFR 91.103
14 CFR 91.109 14 CFR 91.119(c) 14
CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (1) and (2) 14 CFR 91.417(a) and (b)

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Robert W. Lacy, operator of Unmanned A ircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulati ons (“FARs”) to allow commercial operation of designated UAS, provided such operations are conduc ted within and under the conditions outlined herein or as may be established by the FAA as requi red by Section 333. Commercial operation of an UAS, as described herein , which are equipped with camera(s) and sensors, would provide professional services in the following areas:
1. Aerial photography and/or video for public and/or p rivate use including real estate, architecture, construction, land surveying, enginee ring and other related professional activities.
2. Aerial video and/or photography for public and/or p rivate use including television, public events, cinematography and newsgathering.
3. Aerial inspection/photography of residential/commer cial structures under contract with the owners or local government authority.
4. Aerial inspection/photography of residential/commer cial utility infrastructure including but not limited to electrical power lines, wind tur bines and cell towers.
5. Aerial video/photography or providing live video fe ed to assist with search and rescue operations in cases of an emergency or natural disa ster only when the local authorities or government has requested it by contract or donation

. 6. Training to persons individually or belonging to bo th private and/or public organizations to increase awareness and improve safety for curren t and future UAS operations within the NAS. As described fully below, the requested exemption w ould permit the operation of designated UAS as set forth in this document under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) safe. Approva l of this exemption would increase publicawareness of UAS operations and enhance safety to a id in fulfilling the Secretary of

Transportation’s (the FAA Administrator’s) responsi bilities to “....establish requirements for the safe operation of such aircraft systems in the nati onal airspace system.”

Robert W. Lacy plans to operate a UAS, the DJI PHAN TOM 3 Professional which is comprised of an unmanned aircraft (UA or Phantom 3) and a transport able ground station. The Phantom 3 is referred to as a quad-copter with a maximum gross weight of abo ut 3 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s.

Robert W. Lacy also plans to operate a UAS, the DJI Inspire 1 which is comprised of an unmanned aircraft (UA or Inspire 1) and a transportable grou nd station. The Inspire 1 is referred to as a quadcopter with a maximum gross weight of about 6.5 pou nds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 22 m/s.

Also, given the small size of the UAS’s involved an d the restricted controlled environment within which they will operate, the applicant fits within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA m ust, by exemption, allow commercial operations of UASs to commence immediately. Also du e to the size of the UASs and the controlled areas in which the relevant UASs will op erate, approval of the application presents no national security issue. Given the following, the g rant of the requested exemptions is clearly in the public interest: Robert W. Lacy proposes that t he exemption requested herein apply to civil aircraft that have the characteristics and that ope rate with the limitations listed herein. These limitations provide for an exceptional level of saf ety to operations. These limitations and conditions to which Robert W. Lacy agrees to be bou nd when conducting commercial operations under an FAA issued exemption including:

1. The UAS will weigh less than 55 lbs.
2. Flights will be operated within line of sight of op erator.
3. Maximum total flight time for each operational flig ht will be 30 minutes.
4. Flights will be terminated at 15% battery power res erve. 4. Flights will be operated at an altitude of no more than 400 feet AGL
5. UAS operator will be trained and certified in the p roper safety and operations of the UAS.
6. The UAS will only operate within a controlled area as defined in the Procedures.
7. The operator will post advisor notice around the co ntrolled area.
8. The operator will have been trained in operation of UAS generally and received up-to-date information on the particular UAS to be operated as required.
9. If the UAS loses communications or loses its GPS si gnal, the UAS will have capability to return to a pre-determined location within the Security Pe rimeter and land.
10. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

Accordingly, the applicant respectfully requests th at the FAA grant the requested exemption and are prepared to modify or amend any part of this re quest to satisfy the need for an equivalent level of safety. Please contact us at any time if a dditional information or clarifications are needed.Sincerely,

Robert W. Lacy