### United States Department of

### Trimsportatio~ Docket Management System · · 1200 NewJersey Ave., SE

. West Building Ground Floor ROOJTI W12-140 Washington, DC 20590 ' ;· Re: j:xception Request in accordance toSection 333 FAA

### Moderniz~tion and Reform Act of2012

• 1 ·- ' ' : •• : • ' • 

### Iam writing in

### accord~nce

# toSection 333 ofthe FAA

### Moder~izationand Reform Act of2012 to request ' 

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### that I may operate my UAVcommercially in United States airspace. Mydesire is'to use this· UAV to · provide customers with an 'up-high' view oftheir properties, lands or projects. Other usages may include landscape photography and possibly event photography. The UAV I'm proposing to use is a Parrot Bebop Drone (hereafter in this lettercalled a UAV). This is a small device measuring 11"x12.5"x 1.5" and weighingjust under 1 pound. The UAV has atop speed of 25 knots. (http:/ /www.parrot.com/products/bebop-drone/) It comes equipped with a 14mpforward facing camera and four counter-rotating propellers powered by four brushless

### mo~ors.for balance, control and stability.' The Bebop Drone uses GNSS (GPS +GLbNASS),

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### a 3-axes magnetometer, gyroscope and accelerometer, a separate down-facing cameraand an ultrasonic sensorfor att,itude, altitude and flightcontrol. It connects to a remote control wireless at ,2.4ghz or 5ghzconnecting

### byWi~Fi 802.11 a/b/g/h/ac. Tl'iis

### d~vice complies witli Part 15 ofthe FCC Rules. Operation is subjecttothe following two conditions: This equipment may not cause harmful .interference. This equipment must accept any interference received, including interferencethat may

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### cause**~,~n,desired** 

### operation.

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### As this already includesthe camera (software stabilized) there is no reason for any additional payloads ' •. '·.'·: 4i:' : 

### to be attached to it. Nor is itdesigned to handle additional payloads. This device will be used strictlyfor photography and videography, as it has been builtto perform. This UAV utilizes a remote control known as a Skycontroller. This device uses two 36dBm antennas for controlling the UAV and, accordingtothe manufacture, boasts a range of2km. For the practical commercial purposes I envision forthis UAV, I

### don't believe itwill need to exceed even aquarterofthat distance. Most operations with this UAV will involve takingto an altitude to capture photography (not to exceed 200agl) for property or landscape imagery. Atablet or cellphone is utilized for providing afirst-person-view and flight information during operation. Essentially, the camera used to video or photography recording can be controlled and viewed through during fight. In unforeseeable situations where the device mightfall out ofsight, this view can also be utilized to steerthe device back into line-of-sight. Altitude, speed, distance from remote, GPS state, and radio signal strength are relayed tothe tablot or smartphone screen. In addition, the first-person-view also provides a kind ofartificial horizon that conveys the performance ofthe UAV in light wind conditions. In mostsituations, a preflight checklist will consist ofchecking the propellers for any damage (fatigue, chippings, etc.) and making certain otherfittings are on tight and in good condition. Only freshly charged batteries will be used for each flight, regardless ofwhattheir percentage was after an individualflight. The device will be made to sit with its motors offfor several minutes afterthe GPS icon shows a steady signal to ensure a stable lock. (GPS status icon turns from red, toyellowto green depending on signal strength.) The sensors will be calibrated before each flight. Forflights over new or existing homes (as requested by a customer), the UAV will only be operated when there are no personal in the field. (For example: Not during a period oftime when construction is going on.) While the UAV is in flight itwill remain in view. The UAV will not be flown overatwo-lane road ifthere'sconstanttraffic or ifthere are other obstructions in the flight area. Itwill not be flown over highways or people.
An additional spotterwill be called in to assist in areas where the flight may be difficult because of vegetation or other obstructions. This model UAV has roughly 10 minutes offlight time and will be brought 'home' once the battery reaches 25% level. It also features a 'Go Home' feature. When activated the UAV will either lower, or raise itselfto 32ftAGL and proceed to return to its take off location. Duringthis 'automatic' flightthe UAV can still be controlled and overridden. The 'Go Home' feature will also activate after a shorttime if asignal is lost from the controller. The UAV also features an automatic motor cutoffsystem. Ifany propeller makes contact with an object, the dronewill shut down all flight systems. This feature can also be manually activated in flight by pressing the 'Emergency' button. The Pilot in question, Miguel Santiago, has flown this model UAV recreationallyfor over 50 flights and has accrued over 5 hours offlighttime. He wears corrective lenses for near-sightedness as specified by his driver's license. During commercial operationsthe UAV will be software limited to fly at no fasterthan 3 knots (1.5 m/s) and no higherthan 200 agl (60.9 meters). Each flight will be no longerthan 10 minuteswith mostflight seldom exceeding 5 minutes. Once the battery dropsto 25% the dronewill be made to return to its landing area. The UAV will never be operated from a movingvehicle. However, the operator may need to move around (on foot) to keep the UAV within visual line-of-sight and to ensure safety while it's in operation. The UAV will only be operated in good weather conditions, with lowwinds, no precipitation and only during daylight hours. lfforany reason an aircraft is heard orseen approachingthe UAV will be made to land immediately. In all cases during commercial operations, permission will be granted to operate in properties. Atthis time I do notforesee this UAV being utilized in or nearairports. Nordo Iforesee this UAV being utilized outside ofthe United States. The FAA is authorized to exempt aircraftfrom the airworthiness certificate requirement under Section 333 ofthe Reform Act. The legislation permitthe FAA to exempt UAVs from the airworthiness certificate requirement in consideration ofthe weight, size, maneuverability and proximityto areas such as airports and population areas. The UAV I'm requesting to be exempt meetsthese elements.14C.F.R 91.7{a) prohibitsthe operations ofan aircraft without an airworthiness certificate. No such certificate is applicable in the form contemplated by the FAR. This Regulation doesn't apply.
14 C.F.R 91.9{b){2} requires an aircraft manual in the aircraft. As there are no pilots or passengers and since the device is small in size this Regulation is inapplicable. A guide will be presentwith the remote flight controller.
14 C.F.R. 91.121 regarding altimetersetting is inapplicable, as the device does not utilize an altimeter setting. The UAV in question utilizes GNSS for electronicglobal positioning and a 3-axes magnetometer, gyroscope and accelerometerfor attitude and flight control. In addition, at 26 AGL {8 meters) or lower, an ultrasonic sensor provides additional altitude information electronically.
14 C.F.R. 45.23 regarding aircraftto be marked to certain specifications. The UAV in question does not have a cockpit or cabin where such markings will go. In addition, the aircraft is much too small forthe two-inch lettering. Nevertheless, the UAV will be marked contact information in several places so that itcan be noticed.
14C.F.R. 61.113 regarding Private Pilot Privileges and Limitations {PIC). Private pilots are limited to noncommercial operations. In addition, pilottraining may not necessarily ensure remote piloting skills of any particular UAV. While private pilot licensees may understand howto operate inside airspace, airport and navigation skills and communications, this far exceeds the intended operation of my UAV. Finally, the risks to the PIC operatingthe UAV is far less then that ofthe commercial activities outlined in 14 C.F.R. 61.
14C.F.R. 91.119 regarding minimum safe altitudes. 14C.F.R. 91.119 proposes safe altitudes forthe operations ofcivil aircraft. Itallows helicoptersto be operated at lower altitudes in certain conditions. My UAV will never operate at an altitude greaterthan 200 AGL. In most cases, the UAV will operate in areas where no bystanders will be {ie: an emptyfield or residential yard around a home.) In areas where itwill operate for event photography, itwill do so in areas blocked offor marked and closely monitored by spotters. Given the size, weight, maneuverability and speed ofthis UAV, I believe safety can be achieved.
In scenarios where Ifeel safety cannot be reasonably guaranteed the UAV will simply not be utilized.
14 C.F.R. 91.151 regarding fuel requirements forflights in VFR conditions. The UAV uses a Lithium Polymer 1200 mAh batterythat provides it with roughly ten minutes offlighttime. The status of battery power is displayed in two separate places on the remote control and an alert {vibration and audible) will occur ifthe batteryfalls below 10%. My standard procedure is to prepare to land the UAV at 25% battery power. 14 C.F.R. 91.405: Maintenance Inspections. The above regulations require aircraft owners and operators to 1/have [the] aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph {c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter" These regulations only applyto aircraftwith an airworthiness certificate. They will not applytothe UAV in question should its exemption be granted.

### Regardless, the aircraft will be maintained tothe highest standard possible condition, including replacement ofdamaged or missing parts, software updates and constant assessment ofits performance during flight. I believe doing this will maintain the same level ofsafety. In summary, granting me the request for exemption withthis UAV will help to open a marketfor photographyfor construction builders and open a new world of imageryfor citizenry. In the past, such imagerywould only be possible with larger aircraft operating at low altitudes and using flammable fuel. The UAV I'm proposingto use does not contain fuel, is smaller, lighter and much more maneuverable then conventional aircraft. It is also far less distracting and disruptivetothe general publicthen a hovering helicopter or a lowflying fixed-wing aircraft. Since no one is onboard UAVthere is little opportunityfor serious bodily injury during its operation. As mentioned earlier, the UAV 1 pound in weight (belowthe FAA mandated 55 pound limit) and has top speed of25 knots. Horizontal, vertical and rotational speeds can be software limited, adding tothe already significant level ofsafety already inherenttothis UAV. While my desire is to utilize this equipmentfor commercial purposes, safetyto people and property is still my upmost priority. I, Miguel Santiago, respectfully request thatthe FAA grant its exemption to my request. Thank you for your consideration. Sincerely,

# ~.~ Miguel Santiago 5306 Big Bass Drive Raleigh, NC 27610 gl!]_tiago2274@_g_mail.com {910) 494-2274