February 10, 2016

Docket Operations, M

- 30 U.S. Dep artment of Transportation (DOT) 1200 New Jersey Avenue, SE. Room W12

- 1 40, West Building Ground Floor Washington, DC 20590

-0001
Re: Summary Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from certain parts of the FARs.

Dear Sir or Madam : Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Lloyd Wright dba Wright Aerospace Technologies ( “Operator”, or the “Petitioner”) , hereby applies for a summary exemption from the listed Federal Aviation Regulations (“FARs”) to allow it to operate small Unmanned Aircraft Systems (“sUAS”) for aerial data collection, , including, but not limited to aer ial video and photography for corporate videography, real estate photography and videography, special events, documentaries, telev ision production and landscape, commerc ials, music videos, events, construction site and building vide os, and training in sUAS operations under the conditions and limitations set forth in this Petition. The requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is (1) limited, (2) predetermi ned, and (3) would provide safety enhancements to the already safe operations presently using manned helicopters and airplanes. Approval of this exemption would thereby enhance safety and fulfill the FAA Administrator’s responsibilities to “...establish requ irements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.


## The name of the **Petitioner and point of contact**  **is:** Lloyd Wright dba Wright Aerospace Technologies 6105 Garwood Cir Flower Mound, TX 75028 l.wright41@verizon.net 214

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Lloyd Wright has been a certificated pilot since 1988. He currently holds an Airline Transport Pilot rating (3077719) with multiple type ratings and approximately 12,000hrs flying experience. He also maintains currency as a Gold Seal Certificated Flight Instructor (3077719CFI) with single, multiengine land, and instrument ratings. Other FAA certifications include Flight Engineer, turbo jet and Ground Instructor, Instrument. In January 2015 Mr. Wright added FCC Technician radio license (KG5FLH) to his resume. Mr. Wright has conducted operations as an FAA designated check airman for a number of companies in a variety of aircraft and simulators. Lloyd Wright has be en a member of the Academy of ModelAeronautics since 2010. He is also a member of the Aircraft Owners and Pilots Association and a local

leader in the Boy Scouts of America. Mr. Wright has built and flown many types of model rotary wing and fixed wing a ircraft to include aerobatic helicopters and multi rotors. He holds safety in the highest priority in all operations and plans to conduct sUAS operations with the same high standards. The Petition is submitted to fulfill Congress’ goal under Section 333(a ) through (c) of the Reform Act, which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Administrator must determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following: • The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator. Reform Act § 333 (a). If the Administrato r determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333(c) (emphasis added). The Secretary has del egated his aviation authority to the Administrator of the FAA. The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory requirements for civil aircraft, a term defined under § 40101 of the Act, which include s sUASs. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

-44716 of the Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1). 

## Make and Model of Aircraft to be Operated:
Blade Chroma (formerly Blade QX3) Cinestar 8 DJI Phantom 3 DJI Inspire DJI S preading Wings S 800 DJI Spreading Wings S900 DJI Spreading Wings S1000/S1000+ In accordance with the statutory criteria provided in Section 333 of Public Law 112 −95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transpo rtation has determined that these aircraft meets the conditions of Section 333

. Therefore, the FAA has found that relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airwo rthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary.All of these vehicles have built in capability to limit the height they fly above the ground and limit the

distance the y fly from the op erator. The vehicles also have the built

- in capability to return to the launching point if the wireless control link is interrupted or if the operator attempts to exceed any of the height, radius, or airspace limitations programmed into it. The FAA has granted section 333 exemptions for these and similar vehicles. See, e.g. Octocopter, LLC, Exemption No. 14666, Haaksman Media, Exemption No. 14661, First Flight Photography, LLC, Exemption No. 11260, Regulatory Docket No. FAA−2014−0736 (as amended 14 April 2015) (DJI Spreading Wings S1000; DJI Inspire). Blade QX3 Exem ption s : 11737, 11879, 12646 

### Blade Chroma (Formerly Blade QX3) Features: •Advanced SAFE® Plus technology •Return Home function •Uses GLONASS and U.S. GPS for greater accuracy and reliability •Mast

- mounted GPS antenna for superb signal reception 

### Blade Chroma Specifications: Approx. Flying Time 30 minutes Battery 11.1V 3S 6300mAh Li

- Po Motor to Motor Distance 400mm Height 9.50in (242mm) Weight 45.9oz (1.3kg) Motors 780Kv Brush less Outrunner Prop Diameter 260mm Flight Control Link 2.4GHz Video Link 5.8GHz Approx. Video Link Range 1,970ft (600m) GPS Receiver GLONASS and U.S. 

## Regulations from which **relief is requested:** 
14 CFR § 61.23 (a) and (c) 14 CFR § 61.101 (e) (4) and (5) 14 CFR § 61.113 (a) 14 CFR § 61.315 (a) 14 CFR § 91.7 (a) 14 CFR § 91.119 (c) 14 CFR § 91.121 14 CFR § 91.151 (a)(1) 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1) 14 CFR § 409 (a) (1) and (2) 14 CFR § 417 (a) and (b)Relief is requested to the extent necessary to al low the petitioner to operate s UAS to perform aerial

data collection. This exemption is subject to the conditions and limitations listed below. 

## Conditions and Limitations Wright Aerospace Technologies will operate its vehicles o n aerial data collection, aerial photography and videography, and training missions only under the following circumstances: 1. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 2. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude will be reported in feet AGL. 3. The UA will be operated wit hin visual line of sight (VLOS) of the PIC at all times. The PIC will use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license. 4. All operations will ut ilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able to communicate orally at all times; electronic messaging or texting will not occur during flight operations. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the duties required of the VO. 5. The requested exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations of the requested grant of exemption are hereinafter referred to as the operating documents. The operating documents will be accessible during UAS operations and will be made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents, the conditions and limitations will take precedence and be followed. Otherwise, the operator will follow the procedures as outlined in its operating documents. The operator may update or revise its operating doc uments, and track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. If the operator determines that any update or revision would affect the basis upon which the FAA granted the requ ested exemption, the operator will petition for an amendment to its grant of exemption.
6 . Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, wil l undergo a functional test flight prior to conducting further operations under the requested exemption. Functional test flights will only be conducted by a PIC with a VO and will remain at least 500 feet from other people. The functional test flight will be conducted in such a manner so as not to pose an undue hazard to persons and property.
7 . The operator will maintain and inspect the UAS to ensure that it is in a condition for safe operation.8 . Prior to each flight, the PIC will conduct a pre -flight inspection and determine the UAS is in a condition

for safe flight. The pre

-flight inspection will account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the s afe operation of the UAS, the aircraft will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.
9 . The operator will follow the UAS manufacturer’s maintenance, overhaul, replacemen t, inspection, and life limit requirements for the aircraft and aircraft components.
1 0 . Each UAS operated under the requested exemption will comply with all manufacturer safety bulletins.
11 . All PICs will hold either an airline transport, commercial, private, recreational, or sport pilot certificate

. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal governm ent. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
12 . The operator will not permit any PIC to operate unless the PIC demonstrates the ability t o operate the UAS safely in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability safely to operate the UAS in a manner consistent with how the UAS will be operated under this exemption will occur under the terms of the requested exemption. Training operations will only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.
13 . UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.
14 . The UA will not operate within 5 nautical miles of an airpo rt reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or any law enforcement official upon request.
15 . The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
16 . If the UAS loses communications or loses its GPS signal, the operator will cause the UA to return to a predetermined location within the private or controlled access property.
17 . The PIC will abort the flight in the event of unpredicted obstacles or emergencies.18 . The PIC will not begin a flight unless (considering wind and forecast weath er conditions) there is

enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.
19 . All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder will apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the COA attached to the requested exemption.
20 . All aircraft operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 22. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request.
23 . The UA will remain clear and give way to all manned aviation operations and activities at all times.
24 . The UAS will not be operated by the PIC from any moving device or vehicle.
25 . All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are presen t that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the safety of nonparticipating persons’ and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating cl oser to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees, or essential persons are not considered nonparticipat ing persons under the requested exemption.
26 . Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) according to instructions contained on the NTSB Web site: www.ntsb.gov.
27 . Further to protect the interests of the operators of other aircraft and o f persons and property on the ground, Petitioner will maintain liability insurance coverage for all of its sUAS operations.

## Granting the petition would be in the public interest because:

1. The Congress of the United States has determined that early accommodation of sUAS into the National Airspace System advances the public interest. The Committee Report leading the House to adopted H.R. 658 said: "The successful integration of unmanned aircraft systems (UAS) into the National Airspace System (NAS) can support more than 23,000 high

- paying jobs in the United States. . . . The absence of a plan to integrate UASs into the NAS is a barrier to such job c reation . . . ." Granting the Petition represents a step toward such integration, in the absence of a comprehensive regulatory regime for sUAS, and thus would serve the Congressional goal and the public interest. 2. Granting the Petition would facilitate the creation, display, and public distribution of art, long recognized as advancing the public interest. They are at the core of the activities that the First Amendment to the United States Constitution seeks to promote and to protect from governmental restrictions. Creative photography and video art fall well within the First Amendment’s protections. "Entertainment, as well as political and ideological speech, is protected; motion pictures, programs broadcast by radio and television, and live entertainment, such as musical and dramatic works fall within t he First Amendment guarantee. " 3. Granting the petition would enable Petitioner to demonstrate the commercial viability of creating art with new aeronautical technology Commercial creative art is protected as well as non

- commercial art. The Patents and Copyrights Clause of the United St ates Constitution and the copyright statute’s protection of visual art and audiovisual works embody the proposition that more creative effort with respect to these kinds of work will be exerted when the creators are allowed to be paid for their works, thus increasing the production of artistic works. 4. Granting the petition will allow the petitioner to respond to economic incentives to increase its creative production. The result will be an increase in the stock of artistic photography, including video for public enjoyment.
5 . Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation technologies advances the public interest. The FAA itself has recognized the public interest in its role of "Encouraging and developing c ivil aeronautics, incl uding new aviation technology." Granting the Petition will enhance FAA fulfillment of that commitment, thereby serving the public interest. Air commerce flourishes in the United States because of the rapid pace of innovation in aeron autical and associated technologies, followed by their commercialization and their introduction of the marketplace. The drone technology that the Petitioner uses exemplifies the latest innovative leap forward in aeronautical technology. Preventing it from using this in air commerce subv erts achievement of the goal.
6. Granting the Petition will fulfill the Congressional determination that integrating sUAS technology into the NAS serves the public interest. Section 330 of the FAA Modernization and Reform Act of 2012, specifically recognizes the advantages to air commerce obtainable from the deployment of sUAS technologies. It mandated several steps by the FAA to accelerate the availability of these technologies in the National Airspace System, thereby representing a congressional determination that the public interest is served by making these technologies more widely available at the earliest practicable date.The Petition represents a way for the FAA to move incrementally, while still satisfying its congressional

mandate and meeting its obligation to enhance the public interest by making new technologies available by allowing the use of sUAS technologies in a manner that protects the public and the rest of the aviation community from significant risk.
8. The commercial activities by Petitioner proposed in the Petition represent contributions to new forms of air commerce, thereby fulfilling the FAA’s statutory mandate under the 2012 Act. 9. Granting the Petition will enhance aviation safety, thereby advanc ing the public interest. The Petitioner has committed itself in the Petition to safety practices that reduce or eliminate hazards to aircraft in the National Airspace System and to persons and property on the ground. Many others are flying sUAS without reg ard to these hazards. Granting the Petition will offer the Petitioner up as an example of how the FAA is willing to accommodate the new technology when it is constrained by appropriate limitations to enhance safety. It will also allow the Petitioner to be a role model for safe commercial sUAS operations. Users of the National Airspace System are confronted by mushrooming threats from sUAS flown in defiance of the FAA’s ban. Unless the FAA shows some flexibility to accommodate lawful and safe operation of sUAS for legitimate commercial purposes, the level of defiance will increase, intensifying the hazards to manned aircraft and to persons and property on the ground. 

## Equivalent Level of Safety All FARs from which relief has been requested have been addre ssed under Conditions and Limitations. This list has been compiled from existing exemptions and has been shown to have an equivalent level of safety with the FAR or does not apply to sUAS operations. The Petition to use a UAS for aerial data collection a nd its proposed limitations are similar in all material respects to those approved by the FAA . In Grants of Exemption Nos. 11062 to Astraeus Aerial (see 11109 to Clayco, Inc. (see see 11213 to Aeryon Labs, Inc. (see Docket No. , and 12645 to Allied Drones (see Docket No. FAA

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-0804), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. The reasons stated by the FAA for granting Exemption No s. 11062, 11109, 11112, 11213, and 11645 also apply to the situation presented by this Petition.The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform Act

relating to size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national se curity. The Petition justifies grant of the requested exemptions allow the Petitioner to obtain aerial photography with its sUAS. Respectfully,

Lloyd Wright Wright Aerospace Technologies 6105 Garwood Cir Flower Mound, TX 75028 l.wright41@verizon.net 214

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