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 propo sed 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 ca pability 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 even t with a pre

coordinated, 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 unde r 18 lbs., will provide me with the ability toprovide 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 §§ 91.4 05(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 t he 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), Priv ate 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 o f 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 o f 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 includingevasive and emergency maneuvers while maintaining appropriate distances from people, vessels, vehicles, and

structures.

Request Relief from 14 CFR § 91.121 Both UAS uses information genera ted 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 petitio ner 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 ne ed 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 s o as to maintain the highest level of safety.

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