Chris Houseman 3064 5 Mile Road Traverse City, MI 49686 Phone: 231

- 642

-0402 housemanchris729@gmail.com

November 10, 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from 14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45. 11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119(b)(c); 14 C.F.R. 91.121; 14 C.F.R. 151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 91.407; 14 C.F.R. 409; and 14 C.F.R. 91.417. Dear Sir or Madame: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Chris Houseman, an operat or of Small Unmanned Aircraft Systems (“sUAS”) equipped to photograph and film scenery, construction sites, and real estate, applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAS, so long a s such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Approval of exemptions for Chris Houseman will allow commercial operations of sUAS to photograph and film scene ry in rural natural areas, owned construction sites and real estate. The pilot in command (PIC) has 157 documented sUAS flights over the course of 2 years. The requested exemption should be granted because operation of the proposed small UASs conducted in the strict conditions outlined below, will provide an equivalent level of safety, as Congress intended, while still allowing commercial operations. The lightweight aircraft, the DJI Phantom 3, covered by the exemption are far safer than conventional operations conducted with helicopters and fixed

-wing aircraft weighing several thousand pounds containing pilot and crew operating in close proximity to the ground and people below. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight

– each support the re quest. In particular, the sUAS is small, and will operate at slow sp eeds, close to the ground, far from airports and in a low risk, low population environment. In addition, the substantial experience of the PIC weighs heavily in favor of granting the exemption.**Table of Contents**

I. Publishable Summary

.............................................................................................................. . 5 II. II. P etitioner’s Contact information

........................... ............................... .. .............................. 5 A. The sUAS

....................................................................................................................... ....... 6 B. Flight Conditions ........................................................................................................

.... ...... 7 C. Flight Operations ........................................................................................................

... ..... . 7 III. Privacy ................................................................................................

........... .......................... 9 IV. Aircraft and Equivalent Level of Safety ........................................................ .......................... 10 V. Public Interest and Safety ...............................................................

........... ............................ 11 VI. Regulations from Which Exemption is Requested .........................................................

...... . 12 A. 14 C.F.R. 21(h): Airworthiness Certificates...........................

......................... ........... .......... 1 2 A

. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration. ....................

......... .......................... ....... 13 B . 14 C.F.R. 43.11: Content, form, and disposition of records for in spections conducted under parts91 and 125 and §§135.411(a) ( 1) and 135.419 of this c hapter.

.............. . ........ ................... ... 14 C

. 14 C.F.R. 45.11: Marking of products.

. ......................................................................... . .. ............ ... 14 D

. 14 C.F.R. 45.27: Location of marks; nonfixed

-wing aircraft

.. ....................................... ............ ...... 14 E

. 14 C.F.R. 45.29: Size of marks

. ................................................................................. ............. ......... 15 F . 14 C.F.R. 91.7(a): Civil aircraft airworthiness. .............................

........................ ....... ............. ....... 15 G

. 14 C.F.R. 91.9(b) (2): Civil aircraft flight manual, marking, a nd placard requirements.......

........... . 15 H

. 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and p lacard requirements. ....

..... ........... . . 16 I

. 14 C.F.R. 91.103(b) (2): Preflight action.

......... ....................... ..................................... ............ .. . .... 16 J

. 14 C.F.R. 91.105: Flight crewmembers at stations. ........................

...................... ........ . ... ............ . 17 K . 14 C.F.R. 91.113(b): Right

-of

-way rules: Except water operations. .........

................... ............. ... . . 17 L

. 14 C.F.R. 91.119(b) and (c): Mi nimum safe altitudes: General. ..............

............ ......... ............ . . ... 18 M

. 14 C.F.R. 91.121: Altimeter Settings ....................................

...................... ..... . ............. ............ .... 18 N

. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions. ..............

........... ............ ........ ... 19 O

. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required. .

........................ ... ............ ....... 19 P

. 14 C.F.R. 91.215: ATC Transpon der and Altitude Reporting Equi pment and Use ......

........... ..... .. 21 Q

. 14 C.F.R. 91.403: General ...............

....................... ....................................................... ........... ..... 21 R

. 14 C.F.R. 91.405 (a) and (d): Maintenance Required

....................... ....................... .......... ........... 21 S

. 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding, or alteration

................ ......................... ...................... ..................................................... ................ ........... 22 T . 14 C.F.R. 91.409: Inspections ...........................

....................... ................................... ............ ....... 22 U . 14 C.F.R. 91.417: Maintenance records .....................................

..................... ....... ............. .......... 23**Exhibit List**

**DJI Phantom 3 Advanced**  **Documents** Exhibit 1 : DJI Phantom 3 Advanced User Manual.............................................

.... ....... ........... Submitted Separately Exhibit 9: DJI Phantom 3 Advanced Safety Guidelines.......

.................... .............. Submitted Separately Exhibit 2 : DJI Phantom 3 Advanced Quick Start Guide............................

.................. ....... .. .... Submitted Separately Exhibit 3 : DJI Phantom 3 Advanced Intelligent Flight Battery Safety Guidelines

......... .. ........... Submitted Separately Exhibit 4 : DJI Phantom 3 Advanced Disclaimer and Warning.............................

.......... .. ........ Submitted Separately Exhibit 5 : DJI Phantom 3 Advanced.................................................

..................... .................. Submitted Separately Exhibit 6 : DJI Phantom 3 Advanced F eatures................................................
.................................... .............................................. Submitted Separately Exhibit 7 : DJI Phantom 3 Advanced Specifications ....................................

..................... ....... Submitted Separately**I. Publishable Summary** 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Applicant seeks an exem ption from the following rules to operate commercially a small unmanned aircraft system (sUAS) (55lbs or less): 14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103 (b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119(b)(c); 14 C.F.R. 91.121; 14 C.F.R. 151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 91.407; 14 C.F.R. 409; and 14 C.F.R. 91.417
Approval of exe mptions for Chris Houseman will allow commercial operations of the sUAS to photograph and film scenery in rural natural areas, owned construction sites and real estate. The pilot in command (PIC) has 157 documented sUAS flights over the course of 2 years. The requested exemption should be granted because operation of the proposed small UASs conducted in the strict conditions outlined below, will provide an equivalent level of safety, as Congress intended, while still allowing commercial operations. The li ghtweight aircraft, the DJI Phantom 3, covered by the exemption are far safer than conventional operations conducted with helicopters and fixed

-wing aircraft weighing several thousand pounds containing pilot and crew operating in close proximity to the gro und and people below. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual lin e of sight

– each support the request. In particular, the sUAS is small, and will operate at slow speeds, close to the ground, far from airports and in a low risk, low population environment. In addition, the substantial experience of the PIC weighs heavil y in favor of granting the exemption.

**II. Petitioner’s Contact Information**  Chris Houseman 3064 5 Mile Road Traverse City, MI 49686 Tel : 231

- 642

-0402 housemanchris729@gmail.com**III. Chris Houseman** 

The requested exemption will permit the operation of one small unmanned multirotor aircraft, the DJI Phantom 3 Advanced.

2. **The DJI Phantom 3 Advanced** The DJI Phantom 3 Advanced is a small, unmanned multirotor aircraft, weighing 2.82 lbs., inclusive of batteries and technical payload. The rotorcraft can operate at a speed up to 31 knots ( 36 mph). The FAA has previously granted Exemption No. 11138, allowing commercial fligh t of a DJI product. Exhibit 2. The sUAS will have the following specifications: **Airframe** : DJI Phantom 3 Advanced **Dimensions** : 438x451x301mm / 17.24 x 17.75 x 11.85 in. **Flight Control**  **System** : Internal to the DJI Phantom 3 Advanced. This includes the main controller (MC), which receives the battery voltage, capacity, and current, the internal measurement unit (IMU), which receives telemetry data (visible at the ground station), compass, GPS, and radio receiver (Rx). Transmitter (Tx): DJI Inspire Remote Control **Receiver (Rx)** : Internal to DJI Phantom 3 Advanced **Motor** : DJI 2312 **Propelle r**  : DJI 9450, 9

- inch diameter **Data and**  **Video Combined**  **Link** : HD Lightbridge Video Downlink **Camera** : DJI Proprietary **Batteries** : LiPo 4S High voltage battery with 4480 mAh capacity

** Please refer to Exhibits 8

- 15 for further information about the DJI Phantom 3 Advanced

.

**B. Flight Conditions**  The sUAS will be flown in airspace under 400 feet above ground level (“AGL”) and under controlled conditions in a closed set in rural areas. Chris Houseman will only operate its sUAS in VMC, visual meteorologica l conditions: no less than 400 feet below and no less than 2,000 feet horizontally from a cloud or when visibility is at least 3 statute miles from the PIC. The PIC will always make a safety assessment of the risk of every operation, and will only operate when it is determined that no undue hazards are present. The flight crew will consist of one Pilot in Command (PIC ). Additionally, during operations, the re will be two visual observers (VO’s ) will be on the lookout for any trespassers, so that the operat ion can be quickly aborted if someone unauthorized walks into the closed set. However, when flying closer than 500 feet to nonparticipating individuals or structures, there will be barriers between the flight area and the nonparticipants. The sUAS will be used to film nature preserves, wineries, and photograph thesesame areas. The sUAS will be flown over both land and water. Chris Houseman will avoid congested

areas when planning operations, and will work with the local FSDO. Chris Houseman will assess eac h location prior to flight, making sure each location abides by the aforementioned, and is safe for all participants. The PIC will only operate the sUAS when the locations are deemed safe. **C. Flight Operations** The purpose of each sUAS flight will be to film and photograph nature preserves for the motion picture and television industries safely and efficiently. Chris Houseman ’s flight crew will consist of just himself. The DJI Phantom 3 Advanced will have the
“ return to home” function in the flight controller. Exhibit 4; Exhibit 1 . Once the home and safety zones are set, the PIC will perform an extensive preflight safety inspection, which is based on pre

-flight safety inspections for manned helicopters. For flig hts over water, the sUAS’s feet will be fitted with flotation devices in the event of an emergency water landing. **1) DJI Phantom 3 Flight Procedure**  To start the DJI Phantom 3 Advanced, Chris Houseman will follow the procedures set out by the manufacturer beginning on page 8 of the Quick Start Guide, Exhibit 2 to this petition. Additionally, Chris Houseman will conduct a communications check to make su re the transmitter is connected to the DJI Phantom 3 Advanced. After the pre

-flight inspection has been completed and the flight crew is in place, the PIC will begin the flight. When flying the DJI Phantom 3 Advanced, the low battery failsafe is triggere d when the DJI Intelligent Flight Battery is depleted to a point that may affect the safe return of the aircraft. This threshold is automatically determined based on the current aircraft altitude and its distance from the home spot. For more information regarding this safety procedure, please refer to Exhibit 1 . Other than this automated emergency procedure, the PIC will manually control each flight in a visible line of sight.
**IV. Privacy**  There is little concern that the proposed flights will cause invasions of privacy because due to the altitude of the flights, and area of limited populations flights will occur. Any private property filmed or photographed will have written consent from the owner.
**V. Aircraft and Equivalent Level of Safety**  Chris Houseman proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level of safety to operate under the current regulatory structure. These limitations and conditions to which Chris Houseman agrees to be bound when conducting commercial operations under an FAA issued exemption include:
**1.** The sUAS will weigh no more than 55 lbs. **2.** Flights will be operated within line of sight of a pilot. **3.** When flying the DJI Phantom 3 Advanced, the low battery failsafe is triggered when the DJI Intelligent Flight Battery is depleted to a point that may affect the safe return of the aircraft. This threshold isautomatically determined based on the current aircraft altitude and its distance from the home spot.

Please refer to Exhibit 1

. **4.** The sUAS will remain clear and yield the right of way to all other manned operations and activities at all times. **5.** Fligh ts will be operated at an altitude of no more than 400 feet AGL. **6.** Minimum crew for each operation will consist of the sUAS PIC. **7.** Prior to each day’s activity, the PIC will visit the location for filming to determine if it is safe for filming. **8.** The operator will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. **9.** The PIC has gone through 150 flight cycles with the DJI Phantom 3 Advanced, which comprises 40 hours of flight time. The PIC has also spent over 300 hours with a virtual trainer, and operated several other sUAS. **10.** Written and/or oral permission from the landowners/authorized agents of the land over which flights will occur. **11.** All required permissions and permits wi ll be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. **12.** The DJI Phantom 3 Advanced has the capability to abort a flight in case of unexpected obstacles or emergencies. Prior to each flight, two separate safety zones will be programmed into the sUAS autopilot, in the event that the home area is unsafe for an emergency landing. **13.** For DJI Phantom 3 Advanced, if the sUAS and its radio controller disconnects during flight, the system’s failsafe protection will come to the rescue and the multirotor will return to home and land automatically, rather than flying off uncontrollably or landing at an unknown location.
Satisfaction of the criteria provided in Sect ion 333 of the Reform Act of 2012

--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUAS in the film and photography profession pursuant to Chris Houseman’s rules of operation, submitted under seal for proprietary reasons.
**VI. Public Interest and Safety** 

Use of the sUAS will increase ground safety by eliminating the need to have multiple individuals in a helicopter while filming. Manned helicopters pose a risk to the pilots and onboard crew. Comparatively, when flying a sUAS, the pilot and crew are safely on the ground, rather than several hundred feet in the air, as the FAA has previously determined. Exhibit 1 at 11. The limited weight of the DJI Phantom 3 significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event of an incident or accident. Additionally, the sUAS can fly at lower altitudes than manned aircraft and requires less room for takeoff and landing, allowing for flights to take place over smaller areas.

**VII. Regulations from Which Exemption is**  **Requested**

14 C.F.R. 21(h): Airworthiness Certificates Chris Houseman requests an exemption from 14 C.F.R. 21(h), which “prescribes procedural requirements for the issue of airworthiness certificates.” 14 C.F.R. 21.171.The DJI Phantom 3’s small size, weight, speed, and limited operating area associated with the aircraft

and their operation meet the statutory considerations of Section 333. **Equivalent level of safety:** Chris Houseman ’s proposed exemption meets the requirements for an equiva lent level of safety of this section, pursuant to Section 333, base d upon the following factors:
• DJI Phantom 3 Advance : 438x451x301mm / 17.24 x 17.75 x 11.85 in. • Light weight: no more than 55 lbs. inclusive of fuel, battery and technical payload. o DJI Phantom 3 Advance : 6.5 lbs. inclusive of battery and technical payload. • Relatively slow speed: o DJI Phantom 3 Advance : the DJI Phantom 3 Advance can operate at speeds up to 43 knots ( 38 mph). • Operational capacity: DJI Phantom 3 Advance : the low battery level failsafe is triggered when the DJI 12 Intelligent Flight Battery is depleted to a point that may affect the safe return of the aircraft. The warning threshold is automatically determined based on the current aircraft altitude and its distance from the home point. • Proximity to airports: Chris Houseman will only operate in Class G airspace, and will notify ATC and the local FSDO prior to operations, as described above. • Proximity to populated areas: Chris Houseman will only operate in Class G airspace in rural, natural areas and work with the local Flight Standards District Offices to determine which areas to avoid during flights. Local FSDO may carve out areas indicated as yellow in the sectional chart and allow Chris Houseman to fly in these specifically designated carve

-out areas. • Operation within visual line of sight: the PIC will always fly the sUAS within his line of sight. • Location: Chris Houseman will operate in rural remote areas in Class G airspace. • Altitude: no more than 400 feet AGL. • Restricted area in which the sUAS will be operated: as described previously in this petition, the flight crew will act as fence posts to the flight area. The sUAS will not exit that area, and the flight crew will watch for individuals and othe r aircraft entering the space. Flights will be aborted if an intruder enters the area. • Substantial experience of the PIC: the PIC has owned and operated the following models of DJI sUAV’s since 2013: DJI Phantom 1, DJI Phantom Vision, DJI Phantom 2, DJI Phantom Vision 2+, DJI Phantom 3 Advanced, DJI Phantom 3 Professional.
**A . 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, propellers,**  **appliances, or component parts for return to service after maintenance, preventive maintenance,**  **rebuilding, or alteration** Chris Houseman requests an exemption from 14 C.F.R. 43.7. This part provides, inter alia, that the holder of a mechanic certificate or a repair station certificate may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service. **Equivalent level of Safety:** The requested exemption will provide an equivalent level of safety for the DJI Phantom 3 Advance, because Chris Houseman will repair and maintain the sUAS in accordance with the manufacturer’s directions and recommend ations.

**B . 14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted under parts**  **91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.**Chris Houseman requests an exemption from 14 C.F.R. 43.11(b). This part provides, inter alia, for the

listing of discrepancies and placards by inspectors. The sUAS, due to its small size, does not have room for placards to be placed in or on it and no inspections for sU AS have been certified by FAA at the present time. **Equivalent level of safety:** To achieve an equivalent level of safety, Chris Houseman will keep log books of all maintenance and repairs. These log books will include the information meant for the placard s. This meets an equivalent level of safety to 14 C.F.R. 43.11(b) because, as envisioned in the August 8, 2014 Memorandum, “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station,” the log books wi ll be kept at the ground station were the PIC and flight crew will have immediate access to them. **C . 14 C.F.R. 45.11: Marking of products**  Chris Houseman requests an exemption from 14 C.F.R. 45.11. This part provides, inter alia, that the manufacturers of aircraft, engines, propellers, mark such aircraft, engines, or propellers with an approved fireproof identification plate. The sUAS, due to its small size, does not have room for fireproof placards to be placed in it. Any required placards could become h azardous, due to the additional weight and strain placed on the sUAS. Any additional weight or placards on the sUAS could create a risk, due to the small size and nature of the DJI Phantom 3 Advance

. **Equivalent level of safety:** To achieve an equivalent l evel of safety, Chris Houseman will keep information related to the DJI Phantom 3 Advance, including their user manuals and log books at the ground station, and affix their N

- Numbers, once obtained from the FAA Registration Office, as large as practicably possible. The requested exemption provides an equivalent level of safety to 14 C.F.R. 45.11 because the relevant documentation containing the serial numbers will be at the ground station with the PIC, where it will be useable in the event of an emergency.
**D . 14 C.F.R. 45.27: Location of marks** ; **nonfixed**
**- wing aircraft**  Chris Houseman requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, that each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. The DJI Phantom 3 Advance, due to its small size, does not have a cabin, fuselage, boom or tail to display the marks required by §45.23. 14 **Equivalent level of safety:** Chris Houseman has received his N

- Numbers for the DJI Phantom 3 Advance, and will display these marks on the body of the aircraft as large as practicably possible. This exemption provides an equivalent level of safety to 14 C.F.R. 45.27 because the sUAS will be registered wit h the FAA Aircraft Registration Branch. In the event of incident, the sUAS will be traceable to Chris Houseman

. **E . 14 C.F.R. 45.29: Size of marks**  Chris Houseman requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, at subpart (3) that the registration marks for rotorcraft must be at least 12 inches high. Such a display will be impracticable, due to the small size of the sUAS.**Equivalent level of safety:** Chris Houseman will affix its registration number as large as practicably

pos sible on the body of the DJI Phantom 3 Advance

. This exemption provides an equivalent level of safety to 14 C.F.R. 45.29 because the sUAS will be registered with the FAA Aircraft Registration Branch. In the event of incident, the sUAS will be traceable to Chris Houseman

. **F . 14 C.F.R. 91.7(a): Civil aircraft airworthiness**  The FAA has previously stated that no exemption is required for this section in the MPAA Exemptions. Exhibit 1 at 19. Chris Houseman requests the same determination be made for this petition. Alternatively, Chris Houseman requests an exemption from 14 C.F.R. 91.7(a). The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will b e no airworthiness certificate issued for the aircraft should this exemption be granted, no standard will exist for determining airworthiness. Equivalent level of safety: Chris Houseman will keep the DJI Phantom 3 Advance’s maintenance and safety informati on at the ground station, where it will be readily accessible to the PIC and the VO before, during, and after operations. T his exemption provides an equivalent level of safety to 14 C.F.R. 91.7(a) because the PIC, based on his knowledge of the aircraft and the documents available, will be able to make the determination as to the airworthy condition, in accordance with 14 C.F.R. 91.7(b). **G . 14 C.F.R. 91.9(b)**  **(2): Civil aircraft flight manual, marking, and placard requirements** The FAA previously stated tha t no exemption is required for this section. Exhibit 2 at 17. Chris Houseman requests the same determination to be made for this Petition. Alternatively, Chris Houseman requests an exemption from 14 C.F.R. 91.9(b) (2). This part provides: "(b) No perso n may operate a U.S.

- registered civil aircraft... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of 15 this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof." First, there does not currently exist a method of approving manuals for sUAS. Second, given the size and configuration of the sUAS, there is no space to carry such a flight manual on the aircraft. In addition, carrying the manual on the aircraft would be pointless, since there is no pilot or other person on board who could read or use it. The equivalent

– and in fact a greater

- level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. On August 8, 2014, the FAA issued a memorandum entitled “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’ s control station.” This document stated, in part “maintaining these documents at the pilot’s control station would meet the intent of the rule as the pilot would be able to produce the documents for his or her own information or to an FAA inspector.” Exhi bit 1. **Equivalent level of safety:** Chris Houseman will keep its flight manual at the ground station, where both the PIC and VO can access it. An equivalent level of safety to 14 C.F.R. 91.9(b) (2) is provided because the intent of this rule

– the pilot h aving access to this material during flight

– is met.
**H . 14 C.F.R. 91.9(c): Civil aircraft flight manual, ma**  **rking, and placard requirements**Chris Houseman requests an exemption from 14 C.F.R. 91.9(c). This part provides: "(c) No person

may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter." As stated above, Chris Houseman has submitted AC Form 8050

- 1 to the FAA Registration Office in order to obtain his N

- Number (N108FF) , and has obtaine d his N

- Number which will be placed on the body of the aircraft in lettering as large as practicably possible. The sUAS, due to its small size, does not have room to contain fireproof placard or to display aircraft marks in a conventional size. However, Ch ris Houseman will place his N

- Numbers on the “arms” or fuselage of the aircraft in lettering as large as practicably possible, once obtained from the FAA. **Equivalent level of safety:** Chris Houseman has obtain ed his N

- Number (N108FF) from the FAA Registra tion Office and will place it body of the aircraft as large as practicably possible. An equivalent level of safety to 14 C.F.R. 9 1.9(c) is met because the Suas will be registered with the FAA and identifiable in the event of an incident.
**I . 14 C.F.R.**  **91.103(b) (2): Preflight action**  Chris Houseman requests an exemption from 14 C.F.R. 91.103(b)(2). This part provides: "Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— ... (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: ... (2) For civil aircraft other than those specified in paragraph (b) (1) of this section, other reliable i nformation appropriate 16 to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature." Because flights of the sUAS will not be at airports, Part 91.103(b) ( 2) does not apply. **Equivalent level of safety:** The Chris Houseman PIC will, before beginning a flight, become familiar with all available and relevant information concerning the craft and that flight, including wind and temperature. However, as the flights of the sUAS will not begin or end at airports, the airport

related information required in Part 91.103(b)(2) does not apply. As a condition to the approval of exemption, Chris Houseman shall perform the preflight operations set forth in its operations m anual.
**J . 14 C.F.R. 91.105:**  Flight crewmembers at stations. Chris Houseman requests an exemption from 14 C.F.R. 91.105 since this part is not applicable due to the sUAS carrying no flight crewmembers. **Equivalent level of safety:** The requested exemption will achieve an equivalent level of safety because Chris Houseman will not operate the aircraft unless someone is at the controls at all times. Each flight will be manual, with the exception of the DJI Phantom 3 Advance’s emergency return
-to
home and stabilization features. This will achieve an equivalent level of safety to 14 C.F.R. 91.105 because the flight crew will be at their stations at all times during the flight. The stations will not be on the aircraft, but on the ground.
**K . 14 C.F.R. 91.113(b): Right** 
**- of** 
**- way rules: Except water operations**  Chris Houseman requests an exemption from 14 C.F.R. 113(b) to the extent that it applies to overhead aircraft operating at or above 500 feet AGL as the sUAS will be operating no higher th an 400 feet AGL. This part provides: “(b): General. When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shallbe maintained by each person operating an aircraft so as to see and avoid other aircraft. When a

rule of this section gives another aircraft the right

-of way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well clear." For example, if another aircraft is operatin g overhead at 10,000 feet AGL there is no danger posed to that other aircraft if the sUAS is operating under it or ahead of it at or beneath 400 feet AGL. **E quivalent Level of Safety:**  Chris Houseman will operate its sUAS to see and avoid and give way to other aircraft that should enter airspace at or below 400 feet AGL, and will give right

-of

-way to manned aircraft. This will provide an equivalent level of safety to 14 C.F.R. 91.113(b) because the sUAS has significantly greater mobility than a much larger, manned aircraft. As a result, the PIC will be able to react and respond much more quickly than the other pilot.
**L . 14 C.F.R. 91.119(b) and (c): Minimum safe altitudes:**  **General.** Chris Houseman requests an exemption from 14 C.F.R. 91.119 subparts (b) an d (c). This regulation provides: "Except when necessary for takeoff or landing, no person may operate an aircraft b elow the following altitudes: (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.” Chris Houseman requests an exemption to allow it to conduct flight operations closer than 500 feet to vessels, vehicles and structures when the owner/controller of any such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment of the risk of operating closer to those objects and determines that it does not present an undue hazard. Chris Houseman also requests an exemption allowing it to fly closer than 500 feet to participating individuals. **Equivalent level of safety:** Chris Houseman will not operate the sUAS any higher than 400 feet AGL, and the majority of flights will be closer to 100 feet AGL. Furthermore, while Chris Houseman will not be operating over any congested areas, the sUAS will necessarily be flown closer than 500 feet to the natural areas and structures it will be filming (as well as closer than 500 feet to the ground). When planning operations, Chris Houseman will work with local FSDO to determine the proper location for filming. Additionally, prior to e ach operation, Chris Houseman’s flight crew will conduct a safety assessment and will not operate its sUAS without determining that there are no undue safety hazards. Chris Houseman will also have a buffer zone to prevent unauthorized individuals from ente ring into the flight area. Chris Houseman ’s VOs will serve as fence posts on the outer edges of the flight operational area in order to actively monitor the space for unauthorized and nonparticipating individuals. Should one appear, Chris Houseman will safely land the sUAS in a manner meant to avoid the unauthorized/nonparticipating individual. This will provide an equivalent level of safety to 14 C.F.R. 91.119(b) and (c) because the PIC and flight crew will make a safety assessment of the risk of operating, and determine that it does not present an undue hazard.
**M . 14 C.F.R. 91.121: Altimeter Settings** Chris Houseman requests an exemption from 14 C.F.R. 91.121. This Part provides guidelines for

altimeter use in maintaining the cruising altitude or flight level of the aircraft. Chris Houseman is not requesting a general exemption from the requirement that its sUAS have an Altimeter. The DJI Phantom 3 Advance’s flight controller has an internal measurement unit (“IMU”). The IMU has a built

- in internal senso r and a barometric altimeter that measures both attitude and altitude. Exhibit 4, Exhibit 1 . Rather, Chris Houseman requests an exemption from the requirement to set its 18 altimeter to a station along the route, or out of an airport, because the DJI Phantom 3 Advance will not be traveling point

-to
- point and is limited in the distance it can travel from the PIC. Additionally, Chris Houseman will not be flying into or out of an airport. **Equivalent Level of Safety:** Chris Houseman ‘s operation of the sUAS will not exceed 400 feet AGL and will be operated in a fashion that is not a sustained cruising flight such as a manned aircraft will typically fly. The operator will be able to observe and control the maximum height of the sUAS th rough the telemetry features of the transmitter and on the laptop at the ground station. The telemetry features of both the GT80X and DJI Phantom 3 Advance provide altitude information from the onboard flight controller. Additionally, the sUAS will be operated within the line of sight. Therefore, the equivalent level of safety provided by Section 91.121 will be met. The FAA has previously granted this exemption. Exhibit 2.
**N . 14 C.F.R. 91.151: Fuel requirement** **s for flight in VFR conditions** DJI Phantom 3 Advanced is powered by electricity, using lithium polymer batteries that currently have a flight limit of approximately no more than 18 minutes, with optional batteries of 4480 mAh and flight times up to 22 minutes. Exhibit 1 . Therefore, due to the limitat ions of the batteries, it is currently impossible to comply with Part 91.151. However, the sUAS will be operated in a manner with at least the equivalent level of safety as that of a manned aircraft complying with Part 91.151. Operation of a sUAS with le ss than 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was intended to alleviate. During the entire flight, the PIC will always have a visual line of sight of the sUAS and the VO will be monitoring the battery life vi a the telemetry display on the laptop at the ground station. The sUAS will always have enough power to land safely, given the minimum level of reserve capacity of the batteries. When flying the DJI Phantom 3 Advanced , the low battery failsafe is triggere d when the DJI Intelligent Flight Battery is depleted to a point that may affect the safe return of the aircraft. This threshold is automatically determined based on the current aircraft altitude and its distance from the home spot. For more information regarding this safety procedure, please refer to Exhibit 1

. Applicant believes that an exemption from 14 CFR §91.151(a) is entirely consistent with the scope of similar exemptions already granted to other operations, including the MPAA Exemptions. Exhibit 9. **Equivalent level of safety:** Chris Houseman will land the DJI Phantom 3 Advanced when the low battery level failsafe is triggered. The proposed exemption meets an equivalent level of safety to 14 C.F.R. 91.151 because, given the limitations on Chris Houseman ’s proposed operations and the location of those operations, a reduced minimum power reserve for flight in daylight VFR conditions is reasonable.**O .**  **14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required**

Chris Houseman requests an exemption from 14 C.F.R. 91.203(a) and (b). This section provides in 19 part: “(a) except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) an appropriate and current airworthiness certificate... (2) A n effective U.S. registration certificate issued to its owner... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.”
T here are currently no procedures by which the FAA can approve airworthiness certificates for sUAS. However, Chris Houseman has submitted an AC Form 8050

- 1 to the FAA Registrati on Office and has obtain ed his N

- Number (N108FF) , which will be placed on the body of the aircraft as large as practicably possible, and the PIC will have the operator’s manual and log book at the ground station, which have of the relevant testing and data information for each sUAS. Additionally, the autopilot systems for the DJI Phantom 3 Advanced provides a number of safety features, including the failsafe automatic return to home if the radio control link is broken. B ecause of the use of GPS with the s UAS, the operator will set the initial location of flight takeoff ("home position"), and two alternative “safety zones” the sUAS can be directed to, should the home position become unsafe. If the radio control link is broken, the Autopilot system will recognize this broken control link and cause the sUAS to automatically return to the home position as recorded by the GPS instrumentation. Because the sUAS team will mark off an area with traffic cones that has a 50

- 100 foot diameter that will be used as the “ home position” for the sUAS to return, no one will be standing in the way of the path. More information about the DJI Phantom 3 Ad vance’s flight control system can be found on page 12 of its user manual, submitted as Exhibit 1

. In the restricted environm ent and under the conditions proposed, operation of the sUAS will be at least as safe as a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate. Chris Houseman will not accept assignments from clients who are within 5 miles of controlled airspace without first gaining written and/or oral permission from air traffic control. **Equivalent level of safety:** The DJI Phantom 3 is no more than 6 pounds. The sUAS will be tightly controlled and monitored by the operator and th e observer and in compliance with the requirements of the FAA’s grant of this petition and all local public safety requirements. This will ensure safety and security for the area of operation. The FAA will have advance notice of all operations because Chri s Houseman will notify both ATC and the local FSDO prior to operating, as outlined above. These safety enhancements provide a greater degree of 20 safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, and inability to carry a substantial payl oad. Granting the proposed exemption will achieve an equivalent level of safety to 14 C.F.R. 91.203(a) and (b) because of the small size of the sUAS and the operational limits set out above.
**P . 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equ**  **ipment and Use**This section requires that installed Air Traffic Control (ATC) transponder equipment must meet

specific performance and environmental requirements, and aircraft must be equipped with an operable coded radar beacon transponder. The DJI Phantom 3 is not equipped with ATC transponder equipment. It is designed to fly in limited airspace under the control of a ground station. Because the sUAS used by Chris Houseman will not be flying into or near airports, and will fly no higher than 400 feet AGL, they will not share airspace with manned aircraft and there is very low risk of collis ion . In addition, because there will be no need to have contemporaneous communication with ATC Control, due to the short distances, short flight times, and restricted altitude the sUAS will operate within, Chris Houseman requests an exemption from this section. Additionally, the sUAS is too small to contain ATC transponder equipment in any form factor that is known to be available commercially at a reasonable cost. **Equivalent level of safety:** An equivalent level of safety to 14 C.F.R. 91.125 will be met because Chris Houseman will not fly his sUAS into or near airports. All operations wil l be below 400 feet AGL, so there is very low risk of collision with any manned aircraft. The DJI Phantom 3 will always be flown within the line of sight of the PIC

. Chris Houseman will contact local ATC before operations to issue a NOTAM, and the local FS DO with its flight plan. Chris Houseman will also give right of way to manned aircraft as they do appear. **Q . 14 C.F.R. 91.403: General**  This section requires that the owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition. Chris Houseman will adhere to this requirement. However, this Section also limits maintenance to that “prescribed in this subpart and other applicable regulations, including part 43 of this chapter.” Because of this limitation, and because of the exemptions under Part 43 requested above, Chris Houseman requests an exemption from this Section. **Equivalent level of safety:** This exemption meets the requirements for an equivalent level of safety pursuant to Section 333 because of i ts small size, light weight, relatively slow speed, and use in controlled rural environments, as described previously in this petition. Chris Houseman will conduct maintenance and repairs of the DJI Phantom 3 under the supervision and direction of the sUAV’s manufacturer and designer.
**R . 14 C.F.R. 91.405 (a)**  **/ (d): Maintenance Required**  This section requires that aircraft be inspected as prescribed by Section E, 14 C.F.R. 21 §§91.401

-91.421. As shown below, Chris Houseman is applying for an exemption for these sections, due to the fact that its operators will inspect the sUAS prior to each flight and keep a record of all maintenance that is done. Additionally, prior to each operation, Chris Houseman will conduct a pre

flight safety check of the DJI Phan tom 3 . This safety check is listed in the operations manual, submitted confidentially. Because the Sections discussed below are concerned with manned aircraft, and as such have inspection requirements designed for the safety of passengers, they are inappli cable to Chris Houseman

.Chris Houseman is also applying for an exemption to subpart (d) of this section, which requires a

placard to be installed and references §43.11. As noted previously, Chris Houseman requests an exemption to the placard requirement, because, due to the small size of the sUAS, there is no room to place the placard. As an alternative and to achieve an equivalent level of safety, Chris Houseman keeps logbooks detailing all repairs. Despite the requested exemption from subparts (a) an d (d) of this section, Chris Houseman will follow subparts (b) and (c) of this subpart. **Equivalent level of safety:** The requested exemption will meet an equivalent level of safety to 14 C.F.R. 405 (a) and (d) because Chris Houseman will repair and maintain the DJI Phantom 3 by following the manufacturer’s specifications. **S . 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding, or**  **alteration** This section prevents any aircraft from operation that “has u ndergone maintenance, preventative maintenance, rebuilding, or alteration unless (1) [i]t has been approved for return to service by a person authorized under § 43.7 of this chapter; and (2) [t]he maintenance record entry required by §43.9 or §43.11, as ap plicable, of this chapter has been made.” However, Chris Houseman has requested an exemption from §§ 43.7 and 43.11 as described previously. The capability of the operators to maintain and repair the sUAS meets the requirements for an equivalent level of safety pursuant to Section 333 for both sUAS, their intended use, and the rural operating environment. Additionally, due to the small size of the sUAS, there is no room to place inspection placards. Therefore, because Chris Houseman has requested an exem ption from 43.7 and 43.11, Chris Houseman respectfully requests an exemption from 91.407. **Equivalent level of safety:** To achieve an equivalent level of safety, Chris Houseman will regularl y inspect and maintain his sUAS in the manner required for manned aircraft, under the supervision of and at the direction of the manufacturer of the DJI Phantom 3

. Chris Houseman will repair and maintain the DJI Phantom 3 by following the manufacturer’s specifications.
**T . 14 C.F.R. 91**  **.409: Inspections** This section lays out the requirements for inspections of aircraft. Chris Houseman respectfully requests an exemption from these requirements because they are intended to maintain the safety 22 of manned aircraft significantly larger and capable of significantly longer flights than is sUAS. **Equivalent level of safety:** The requested exemption will meet or exceed the level of safety achieved by adherence to 14 C.F.R. 91.409 because Chris Houseman ’s inspection and maintenance procedures of the DJI Phantom 3 are as identical as possible to the inspection and maintenance procedures of manned aircraft. Chris Houseman will repair and maintain the DJI Phantom 3 by following the manufacturer’s specifications.
**U . 14 C.F.R. 91.417: Maintenance re** **cords**Chris Houseman respectfully requests an exemption from this Section, as it is only applicable for

aircraft with an airworthiness certificate. Because Chris Houseman will not have an airworthiness certificate, this Section is inapplicable. **Equivale nt level of safety:**  The requested exemption will provide an equivalent level of safety to 14.C.F.R. 91.417 because Chris Houseman will keep detailed maintenance records on every part as it is replaced, including but not limited to propellers, batteries, an d electrical components.