Michael Gould

This following serves as a summary, which you may 

publish in the Federal Register:

Manned aircraft conducting aerial photography operations 

can weigh thousands of pounds or more, are operated by an 

onboard pilot and may carry other onboard crew members, 

as well as carry large quantities of fuel. The petitioner’s 

unmanned aircraft (UAS) #1 (DJI Inspire 1) weighs 

approximately 6lbs.-7oz. UAS #2 (DJI S-900) weighs 

approx.18 lbs. The pilot and crew will be remotely located 

from the aircraft. The limited weight and construction 

reduces the potential for harm to persons or damage to 

property in the event of an incident or accident. The risk to 

an onboard pilot and crew during an incident or accident is 

eliminated with the use of a UAS for the proposed 

operations. Manned aircraft are at risk of fuel spillage and 

fire in the event of an incident or accident. The UA carries no 

fuel and therefore the risk of fire following an incident or 

accident due to fuel spillage is eliminated. 

Both UAS have the capability to operate safely after 

experiencing certain in-flight contingencies or failures and 

use an auto-pilot system to maintain UAS stability and 

control. Both UAS are also able to respond to a loss of global 

positioning system (GPS) or a lost-link event with a precoordinated, predictable, automated flight maneuver. 

These safety features provide an equivalent level of safety 

compared to a manned aircraft holding a restricted 

airworthiness certificate performing a similar operation. Both 

UAS being under 18 lbs., will provide me with the ability to 
provide aerial vistas for my customers, without resorting to 

the high cost, high noise, passenger, crew, fuel explosion 

danger, and waste of fossil fuels, thereby providing public 

benefit with limited impact. Manned aircraft are at risk of fuel 

spillage and fire in the event of an incident or accident. Both 

UAS carries no fuel, and therefore the risk of fire following an 

incident or accident due to fuel spillage is 

eliminated.Request relief from 14 CFR §§ 91.405(a) 

Maintenance required, 91.407(a)(1) Operation after 

maintenance, preventive maintenance, rebuilding, or 

alteration, 91.409(a)(2) Inspections, and 91.417(a) and (b) 

Maintenance records. Operating documents contain preflight 

and post flight checks for the UAS. Request relief from § 

91.409(a)(1) because of alternate inspection requirements of 

§ 91.409(a)(2). Operating documents, as should be sufficient 

to ensure that safety is not adversely affected. 

Requested relief from 14 CFR § 61.113(a) and (b), Private 

pilot privileges and limitations. I plan to operate in 

uncontrolled airspace and over private property with 

controlled access. Given: 1) the similar nature of the 

petitioner’s proposed operating environment to that of 

Astraeus, 2) the parallel nature of private pilot aeronautical 

knowledge requirements to those of commercial 

requirements as discussed in Exemption No. 11062, and 3) 

the limited airmanship skills necessary to operate the UAS, 

the FAA found that the additional manned airmanship 

experience of a commercially certificated pilot, would not 

correlate to the airmanship skills necessary for the 

petitioner’s specific proposed operations. 

As the PIC, I have private pilot license issued by the FAA 

and have several hundred hours in fixed-wing aircraft. I will 

operate the UAS in a manner consistent with and including 
evasive and emergency maneuvers while maintaining 

appropriate distances from people, vessels, vehicles, and 

structures. 

Request Relief from 14 CFR § 91.121 Both UAS uses 

information generated from GPS to transmit altitude 

information to the PIC.Requested relief from § 91.151(a) 

Fuel requirements. No fuel required. Similar UAS- specific 

relief has been granted in Exemption Nos. 8811, 10808, and 

10673 for daytime, VFR conditions. The petitioner proposes 

to land the UAS after a maximum of 10-12 minutes in flight, 

or prior to 40% battery power remaining. The operating 

documents indicate that the UAS will return to the launch 

point and land when the battery reaches 30% of capacity. I 

will not need to, nor shall I, operate within 5 NM of an airport. 

I will comply with all NOTAMs. I am familiar with the drone 

“No Fly” zones and I review these maps prior to each flight. I 

have a four-page pre-flight checklist, which I use for each 

and every flight so as to maintain the highest level of safety.

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