US	Department	of	Transportation	Exemption	Request	Pursuant	to	Section	333	of	the

FAA	Modernization	and	Reform	Act	of	2012

November	24,	2015
Wayne M. Lane 7319	Bridlespur	Lane Delaware,	OH	43015
US	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Avenue,	SE Washington,	DC	20590
Re:	Exemption	Request	Pursuant	to	Section	333	of	the	F ederal Aviation Administration	(FAA) Modernization	and Reform	Act of	2012	of	the	Federal Aviation	Regulations	(FARs)	from :	14	CFR Part 21 Subpart	H ; 14 C FR	45.23 (b); 14 CFR	61.113(a)&(b); 14	CFR	91.7 ;	14	CFR	91.9(b) (2); 14	CFR	91.103; 14	CFR	91.109; 14	CFR	9 1.119 (d); 14	CFR	91.121;	14	CFR	91.151 (a) ;	14	CFR	91.203(a) & (b);	CFR 91.405 (a);	14	CFR	91.407 (a)(1);	14	CFR	91.409 (a) (2);	14	CFR	91.417(a) & (b).

Dear Sir	or	Madam:

P ursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	( FMRA) and the	procedures	contained	within 14	CFR	Part	11 , I, Wayne M. Lane, operator	of Unmanned	Aircraft	Systems	(UAS), request	exemption from	the	listed	FARs	to	allow commercial	operation	of	designated	UAS,	provided	such	operations	are	conducted within	and	under	the	conditions	outlined	herein	or	as	may	be	established	by	the FAA	as	required	by	Section	333.The	approval	of	this	exemption	will	aid	in	public	awareness	of UAS	operations,

capabilities,	and	limitations.	The	establishment	of	requirements	for	the	safe operation	of	such	aircraft	helps	to	fulfill	the	FAA	stated	goal:	“The	FAA’s	continuing mission	is	to	provide	the	safest,	most	efficient	aerospace	system	in	the	wo rld.”
Thank	you	for	your	consideration. Wayne M. LaneCommercial	operation	of	UAS,	as	described	herein,	which	are	equipped	with

cameras	and	sensors,	would	provide	professional	services	in	these	areas:

1. Aerial	photography	and	video	for	public	and	or private	use	including	real estate,	architecture,	land	and	agriculture	surveying	and	other	related professional	activities. 2. Aerial	video	and	photography	for	public	and	or	private	use	including television,	public	events,	cinematography, and	newsgathering. 3. Ae rial	inspection	and	photography	of	residential	commercial	structures under	contract	with	owners	or	local	government	authority. 4. Aerial	inspection	and	photography	of	residential/commercial	utilities	power lines,	cell	towers , and	wind	turbines. 5. Aerial	photography	and	video	for	first	responder	organizations	to	assist	in search	and	rescue	or	natural	disasters	when	deemed	necessary	by authorities	by	contract	or	donated	services 6. Training	for	individuals	or	groups	to	increase	public	awareness	of	the	uses and	limitations	of	UAS	operations.
As	detailed	below,	the	requested	exemp tion	would	permit	the	operation of designated	UAS	as	set	forth	in	this	document	under	controlled	conditions	in	the	NAS that	would	be	(a)	limited,	(b)	controlled,	(c)	predetermined,	and	(d)	sa fe. Approval of	this	exemption	would	increase	public	awareness	of	UAS	operations	and	enhance safety	to	aid	in	fulfilling	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s) responsibilities	to	“...establish	requirements	for	the	safe	operation	of	such aircraft systems	in	the	national	airspace	system.”
The	name	and	address	of	the	applicant	is: Wayne M. Lane 7319	Bridlespur	Lane Delaware,	OH	43015 wmlane@me.com

E xemption	from	the	following	regulations is	requested :
14	CFR	Part	21	subpart	H14	CFR § 45.23 (b)

14	CFR §61.113(a)&(b ) 14	CFR § 91.7 14	CFR § 91.9(b) (2) 14	CFR §91.103 14	CFR § 91.109 14	CFR § 91.119 ( d) 14	CFR § 91.121 14	CFR § 91.151 14	CFR § 91.203(a)& (b) 14	CFR § 91.405 (a) 14	CFR § 91.407(a) (1) 14	CFR § 91.409(a) (2) 14	CFR § 91.417(a)& (b)
Wayne M. Lane	will	operate	one	or	more	of	the	following	model	UAS: Chroma	CG02	+	Stabilized	1080P	Camera **The	Aircraft	Specifications** Chroma	CG02	+	Stabilized	1080P	Camera Approximate	Flying	Time 30	Minutes Battery 1 1 .1 V 3S 6300 mAh	Li

- Po Motor	to	Motor	Distance 400	mm Height 9.5 0 in	(242	mm) Weight 45.9	oz	(1.3	kg) Motors 780	Kv	Brushless	Outrunner Prop	Diameter 10.2	in	( 260	mm) Flight	Control	Link 2.4 GHz Video	Link 5.8 GHz Approximate	Video	Link	Range 1970	ft (600	m) GPS	Receiver GPS,	GLONASS Recommended	Environment Outdoor DJI	Phantom	3**Aircraft**

Diagonal	Size	(including	propellers) 590	mm Max	Ascent	Speed 5	m/s Max	Descent	Speed 3	m/s Hover	Accuracy  Vertical:+/

- 0.1	m	(when	Vision Positioning	is active)	or	+/

- 0.5	m
 Horizontal:+/

- 1.5	m Max	Speed 16	m/s	(ATTI	mode,	no	wind) Max	Altitude	Above	Sea	Level 6000	m Operating	Temperature 0°C	to	40°C GPS	Mode GPS/GLONASS
**Camera** Sensor Sony	EXMOR	1/2.3”	Effective	pixels:	12.4 M	(total	pixels:	12.76 M) Lens FOV	94°	20	mm	(35	mm	format equivalent)	f/2.8,	focus	at ∞ ISO	Range 100

- 3200	(video)	100

- 1600	(photo) Shutter	Speed 8s

- 1/8000s Image	Max	Size 4000	x	3000 Still	Photography	Modes  Single	Shot
 Burst	Shooting:	3/5/7	shots
 Auto	Exposure	Bracketing (AEB):	3/5
 Bracketed	Frames	at	0.7EV	Bias
 Time

- lapse Video	Recording	Modes Phantom	3	Professional
 UHD: o 4096x2160p	24/25, o 3840x2160p	24/25/30
 FHD: 1920x1080p	24/25/30/48/50/60
 HD: 1280x720p	24/25/30/48/50/60 Supported	SD	Card	Types Micro	SD Max capacity:	64GB. Class	10	or	UHS

- 1 rating	required Max	Bitrate	of	Video	Storage Phantom	3	Professional
 60	Mbps Supported	File	Formats  FAT32/exFAT
 Photo:	JPEG,	DNG
 Video: MP4,	MOV (MPEG

- 4 AVC/H.264) Operating	Temperature 0°C	to	40°C**Gimbal**

Controllable	Range Pitch

- 90°	to	+30° Stabilization 3

- axis	(pitch,	roll,	yaw) **Vision	Positioning** Max	Velocity Less	than	8	m/s	(when	2	m	above ground) Altitude	Range 50cm

- 300cm Operating	Range 50cm

- 300cm Operating	Environment Surface	with	clear pattern	and	adequate lighting	(Lux>15)
**Remote	Controller** Operating	Frequency 2.400	GHz

- 2.483	GHz Max	Distance  Up	to	5	km	or	3.1	miles (unobstructed,	free	of	interference) when	FCC	compliant
 Up	to	3.5	km	or	2.1	miles (unobstructed,	free	of interference) when	CE	compliant Video	Output	Port USB Operating	Temperature 0°C	to	40°C Battery 6000	mAh	LiPo	2S Mobile	Device	Holder For	tablet	or	phone Receiver	Sensitivity	(1%PER)

- 101	dBm±2	dBm Transmitter	Power	(EIRP)  FCC:	20	dBm
 CE:	16	dBm Working	Voltage 1.2	A	@7.4	V **Battery	Charger** Voltage 17.4	V Rated	Power Phantom	3	Professional
 100	W **Intelligent	Flight	Battery** Capacity 4480	mAh Voltage 15.2	V Battery	Type LiPo	45 Energy 68	Wh Net	Weight 365	g Max	Flight	Time Approximately 23	minutes Operating	Temperature

- 10°C	to	40°C Max	Charging	Power 100	W**Aircraft	and	Equivalent	Level	of	Safety**

Given	the	size	and	endurance	of	the	UAS,	its	safety	features,	and	operator experience,		the	approval	of	this	application	presents	no	securi ty	threats.
Regarding	the	level	of	safety	surrounding	the	proposed	operations	and	the	public benefit

— reduction	in	environmental	impact,	which	includes	but	is	not	limited	to reduced	emissions	and	noise

— the	requested	exemption	is	in	the	public	interest.	As such,	the	applicant	respectfully	asks	that	the	FAA	grant	the	requested	exemption.

Th e	limitations	and	conditions	the	applicant	is	proposing	when	conducting commercial	operations	under	the	FAA

- issued	exemption	as	set	forth	in	the	Flight Operations	Manual	( FOM)	include:

1. The	UAS	will	weigh	significantly	less	than	55	lbs,	which	is	the	proposed	weight limit.	The	total	weight	of	the	UAS,	including	battery	and	camera,	is	less	than	5 lbs.
2. The	UAS,	depending	on	which	model	is	in	operation,	will	have	a maximum operating	speed	of	less	than	30	mph.
3. All	flights	will	be	operated	within the line	of	sight	of the	Pilot	in	Command	(PIC) and/or	Visual	Observer	(VO).
4. Maximum	flight	time	will	not	exceed	30	minutes.	Flights	will	be	terminated when no	less than	25 %	battery	power	remaining. 5. Flights	will	be	operated	at	an	altitude	no	greater	than	500	ft.	above	ground	level (AGL)
6. Minimum	crew	complement	for	all	operations	will	consist	of	the	UAS PIC and	at least	one VO .	A	third	observer,	a	Camera	Operator,	may	be	utilized.
7. The	UAS	pilot	will	be	designated PIC .	The	PIC	will	have	logged	a	minimum	of	25 hours	operating	the	designated	UAS.
8. Prior	to	each	flight, the	PIC will inspect	the	UAS	to	ensure	that	it	is	in	an airworthy	condition	and	safe	for	flight.	All	maintenance will be	properly documented	in	the	aircraft	records.9. A	safety	briefing	will	be	conducted	prior	to	all	flight	operations.	All	flight

activities	will	b e	documented.
10. All	flights	will	operate	under	VFR	flight	conditions	during	daylight	operations only. If	flight	at	night	is	required,	a	special	request	will	be	made	at	the	FAA	office closest	to	the	proposed	area	of	operations.
11. The	UAS	may	not	be	op erated	within	5	nautical	miles	of	an	airport	reference point	as	denoted	on	a	current	FAA	published	aeronautical	chart	unless	a	letter	of agreement	with	that	airport’s	management	is	obtained. 12.	If	the	UA S	loses	communications	or its	GPS	signal,	it	must	r eturn	to	a predetermined	location	within	the	planned	operating	area	and	land	or	be recovered i n	accordance	with	the	operating	documents. 13.	The	operator	will	carry	out	its	maintenance,	inspections,	and	record

- keeping requirements in	accordanc e	with	the	o perating	documents. Maintenance, inspection,	alterations,	and	status	of	replacement/overhaul	component	parts must	be	noted	in	the	aircraft	records,	including	total	time	in	service,	description of	work	accomplished,	and	the	signature	of	the	authorized	perso n	returning	the UAS	to	service.	Each	UAS operated	under	this	exemption	must	comply	with	all manufacturer safety	b ulletins 14.	The	operator	will	obtain	an Air	Traffic	Organization	(ATO)

- issued	Certificate of Waiver	or	Authorization	(COA)	prior	to conducting	any	operations	under	the grant	of	exemption.	This	COA	will	also	require	the	operator	to	request	a	Notice to	Airman	(NOTAM)	not	more	than	72	hours	in	advance,	but	not	less	than	48 hours	prior	to	the	operation.	All	operations	shall	be	conducted	in accordance with	airspace	requirements	in	the	ATO	issued	COA	including	class	of	airspace, altitude	level, and	potential	transponder	requirements. 15.	All	aircraft	operated	in	accordance	with	the	exemption	must	be	identified	by serial	number,	registered	in accordance	with	14	CFR part	47,	and	have identification	(N

- Number)	marki ngs	in	accordance	with	14	CFR part	45, Subpart	C.	Markings will be	as	large	as	practicable. 16.	The	PIC	and	VO	will	have	b een	trained	in	operation	of	UAS received	current informatio n	for	the	UAS	operated. 17.	The	PIC	and	VO	will	be	in	constant	communication	by	voice	and/or	radio	at	all times. 18.	The	UA S shall	remain	clear	and	give	way	to	all	manned	aviation	operations	and activities	at	all	times. 19.	The	UAS	shall	not	be	operated by	the	PIC	from	any	moving	device	or	vehicle.20.	Written	and/or	verbal	permission	and	permits	will	be	obtained	from	territorial,

state,	county, or	city	jurisdictions,	including	law	enforcement,	fire, or	other appropriate	governmental agencies	as	appropriate	to	flight	operations. 14	CFR	Part	21,	Subpart	H: Airworthiness Certificates, 14	CFR	§91.203(a) (1)

. Subpart H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for the	issuance	of	airworthiness	certificates	as	required	by 14	CFR §91.203(a) (1). Given	the	size	and	limited	operating	area	associated	with	the	aircraft	to	be	utilized by	the	applicant,	an	exemption	from	Part	21 Subp art H meets	the	requirements of
an equivalent	level	of	safety	under	Part	11	and	Section	333	of	the	Reform	Act.	The Federal	Aviation	Act	(49	USC§44701 (f))	and	Section 333	of	the	Reform	Act	both authorize	the	FAA	to	exempt	aircraft	from	the	requirement	for	an	airworthiness certificate,	upon	consideration	of the	size,	weight,	speed,	operational	capability, and proximity	to	airports	and	populated	areas	of	the	particular	UAS.	In	all	cases,	an analysis of	these	criteria	demonstrates	that	the	UAS	operated	without	an airworthiness	certificate	in the	restricted	environment	and	under	the	conditions proposed	will	be at	least	as	safe,	or	safer,	than	a	conventional	a ircraft	(fixed

- wing	or rotorcraft)	operating	with	an	airworthiness	certificate	without	the	restrictions	and conditions	proposed.	The	UAS	to	be	operate d	hereunder	is	less	than	55	lbs fully loaded,	carries	ne ither	a	pilot	nor	passenger,	carries	no	explosive	materials or flammable	liquid	fuels,	and	operates	exclusively	within	a	secured	and	designated
area. Unlike	other	civil	aircraft,	operations	under	this	exemption	will	be	tightly controlled	and	monitored	by	b oth	the	operator	and	under	the	requirements	and	in compliance	with	local	public	safety	requirements.	These	safety	enhancements provide	a	greater	degree	of	safety	to	the	public	and	property	owners	than conventional	operations	conducted	with	airworthiness ce rtificates	issued	under	14 CFR Part	21,	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,	lack	of	explosive materials	or	flammable liquid	fuels,	and	inability	to	carry	a	substantial	external	load.14 CFR §45.23 (b) Display	of	marks;	general

. The	regulation states : “ (b) When	marks include only	the	Roman	capital	letter	‘N’ and	the	registration	number	is	displayed on limited,	restricted, or	light

- sport	category	aircraft	or	experimental	or	provisionally certificated	aircraft,	the	operator	must	also	display	on	that	aircraft	near	each entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	inches	nor more	than	6	inches	high,	th e	words	‘limited,’	‘restricted,’	‘light

- sport,’	‘experimental,’ or	‘provisional,’ as applicable. ” Even	though	the	UAS	will	have	no	airworthiness certificate,	an	exemption	may	be	needed as	the	UAS will	have	no	entrance	to	the cabin,	cockpit	or	pilot	station	on	which	the	word “ Experimental ” can	be	placed. Given	the	size	of	the	UAS, 2

- inch lettering	will	be	impossible.	The	equivalent	level of	safety	will	be	provided	by marking	the	fuselage of	the UAS	as	required	by §45.29 (f) Size	of	marks, where the PIC , VO , and	others	working	with	the	UAS can	see that the	UAS is	marked as “ Experimental. ”
14	CFR	§ 61.113(a)&(b) Private	p ilot privileges	and	limitations:	Pilot in comman d

. The	regulation	states: “(a)	...no	person	who	holds	a	private	pilot	certificate	may	act
as	a PIC of	an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or hire;	nor	may	that	person,	for	compensation or	hire,	act	as	a	PIC of	an	aircraft.	(b)	A private	pilot	may,	for	compensation or	hire,	act	as	a	PIC of	an	aircraft	in	connection with any	business	or	employment	if: (1)	The	flight	is	only	incidental	to	th at	business	or	employment;	and (2)	The	aircraft	does	not	carry	passe ngers	or	property	for	compensation	or hire.” The	proposed	UAS	operations	may	achieve	an	equivalent	level	of	safety	as	achieved by	current	regulations	because	the	applicant’s	UAS	carries	neither	passengers	nor property.	The	risks	atte ndant	to	the	operation of	UAS	are far fewer than	the	risks inherent	in	the	commercial	activities	outlined	in 14	CFR	61 .	The	PIC	of	the	UAS	will be,	or	be	directly	supervised	by,	a	FAA	Certificated	Private	Pilot	with	current	Third Class or	higher	medical	certificate .	It	is	believed	that	the	operation	and	limitations set	forth	in	the	FOM will equate	to the	safe	operation	of	the	UAS.14 CFR §91.7 (a) Civil	aircraft	airworthiness

. T he	regulation	states : “(a)	No	person

may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy condition. ” As	there	will	be no	airworthiness	certificate issued	for	the	aircraft,	should	this	exemption	be granted, no	FAA	regulatory	standard	will	exist	for	determining	airworthiness. B ecause	the	UAS	will	be	fully	maintained	and	operated	in	accordance	with	all specifications	and	requirements	identified	by	the	manufacturer, an	equivalent	level of	safety	will	be	provided.
14	CFR	§ 91.9(b) (2) Civil a ircraftf light m anual

,	marking,	and	placard	requirements

. Section	91.9	(b)(2)	provide s: No	person	may	operate	a	U S	registered	civil	aircraft

— (2) “For	which	an	Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by § 21.5	of 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.”	The	UAS,	given its	size	and	configuration,	has	neither	the ability	nor	capacity	to	carry	such	a	flight	manual	on	board.	In	addition,	there	is no pilot	on	board	to	utilize	or	benefit	from	such	materials.	The	equivalent	level	of	safety will	be	maintained	by	keeping	the	flight	manual	at	ground	control	where	the PIC flying	the	UAS	will	have	immediate	access	to	it.
14	CFR	§91.103 Preflight	action. This	regulation	states	that	“Each	pilot	in	command, shall,	before	beginning	a	flight,	become	familiar	with	all	available	information concerning	that	flight.	This	information	must	include

— (a)	For	a	flight	under	IFR	or a	flight	not	in	the	vicinity	of	an	ai rport,	weather	reports	and	forecasts,	fuel requirements,	alternatives	available	if	the	planned	flight	cannot	be	completed,	and any	known	traffic	delays	of	which	the	pilot	in	command	has	been	advised	by	ATC; (b)	For	any	flight,	runway	lengths	at	airports	of intended	use	and	the	following takeoff	and	distance	information:	(1)	For	civil aircraft	for	which	an	approved Airplane	or	Rotorcraft	Flight	Manual	containing	takeoff	and	landing	distance	data	is required,	the	takeoff	and	landing	distance	data	contained	th erein;	and	(2)	For	civil aircraft	other	than	those	specified	in	paragraph	(b)(1)	of	this	section,	other	reliable information	appropriate	to	the	aircraft,	relating	to	aircraft	performance	underexpected	values	of	airport	elevation	and	runway	slope,	aircraft gross	weight,	and

wind	and	temperature.”	An	exemption	is	requested	from	section	91.103,	as	FAA

approved	rotorcraft	flight	manuals	will	not	be	used.	In	the	absence	of	the	flight manuals,	the	PIC	will	take	all	pre

- flight	actions,	including	reviewing	weather,	flight battery	requirements,	landing	and	takeoff	distances,	and	aircraft	performance	data before	starting	a	flight.
14	CFR	§91.109 Flight	instruction;	Simulated	instrument	flight	and	certain	flight	tests

. Section	91.10 9 provides	that	no	person	may	operate	a	civil	aircraft	(except	a manned	free	balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has fully	functioning	dual	controls.	UAS	and	remotely	piloted	aircraft,	by	their	design	do not	have	fully	functional	dual	controls.	Flight	con trol	is	accomplished	through	the use	of	a	control	box	that	communicates	with	the	aircraft	via	radio	communications. The	FAA	has	approved	exemptions	for	flight	training	without	fully	functional	dual controls	for	a	number	of	aircraft	and	for	flight	instructi on	in	experimental	aircraft. The	equivalent	level	of	safety	is	provided	by	the	fact	that	neither	a	pilot	nor passengers	will	be	carried	in	the	aircraft, and	by	the	size	and	speed	of	the	aircraft.

14 CFR §91.119 Minimum	safe	altitudes:	General

. Section 91.119 establishes	safe altitudes	for	operation	of	civil	aircraft. §91.119 (d) (1) allows	helicopters	to “be operated without	hazard	to	persons	or	property	on	the	surface at less than	the minimums	prescribed... provided each person	operating	the	helicopter	com plies with any	routes or	altitudes specifically	prescribed	for	helicopters	by	the	FAA. ” As this	exemption	is	for	a	UAS	and	the	exemption	requests	authority	to	operate	at altitudes	up	to	400 AGL,	or	not	more	than	200	feet	above	an	elevated	platform	from whi ch	filming	is	planned,	an	exemption	may	be	needed	to	allow	such	operations. As set	forth	herein,	the	UAS	will	never	operate	at	higher	than	400	AGL	with	the exception	of	circumstances	in	which	the	UAS	would	be	used	to	survey	or photograph	a	structure	in	exc ess	of	400	feet	AGL.	In	these situations ,	the	UAS	would not	be	operated	more	than	200	feet	above	the	highest point	on	the	structure. It	will, however,	be	operated	in	a	restricted	area	with	a	security	perimeter,	away	frombuildings	and	where	people	will	not	be	exposed	to	operations	without	their	prior

consent.	The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	and speed	of the	UAS,	as	well	as	the location in	wh ich	it	will	be	operated .	No	flight	will	be taken	without	the	permission	of	the	property	owner	or	local	officials.	Because	the property	owner	and	participants	in	the	filming	activities	will	be	notified	in	advance of	the se	activities,	all	affected	individuals	will	be	aware	of	the	planned	flight operations. Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighing significantly	more	than	the	maximum	of 55	lbs proposed	herein	and	the	lack	of flammable	fuel,	any	ris k	associated	with	these	operations	is	far	less	than	those presently	associated	with	conventional	aircraft	operating	at	or	below	500	AGL. In addition,	the	low

- altitude	operations	of	the	UAS	will	ensure	separation	between these	UAS	operations	and	the	operati ons	of	conventional	aircraft	that	must	comply with	Section	91.119.
14	C.F.R.	§91.121 Altimeter settings.	This	regulation	requires	each	person	operating an	aircraft	to	maintain	cruising	altitude	by	referen ce	to	an	altimeter	that	is	set to “... the	elevation of	the	departure	airport	or	an	appropriate	altimeter	setting available before	departure.”	As	the	UAS	may	not	have	a	barometric	altimeter,	but in stead	GPS	altitude	readout,	an exemption	may	be	needed.	An	equivalent	level	of safety	will	be	achieved	by	the op erator,	pursuant	to	the	safety	checklist	and	live flight	dual	monitoring,	confirming	the	altitude	of	the	launch	site	shown	on	the	GPS altitude	indicator	before	flight.
14	C.F.R.	§ 91.151(a) Fuel	requirements	for flight	in	VFR	conditions.	Section	91.151 (a) prohibits	an	individual	from	beginning	"a	flight	in	an	airplane	under	VFR	conditions unless	(considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to fly	to	the	first	point	of	intended	landing,	and, assuming	normal	cruising	speed (1) Durin g	the	day,	to	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after that	for	at	least	45	minutes."	The	applicant	believes	that	an	exemption	from	14	CFR §91.151(a)	falls	within	the	scope	of	prior	exemptions.Operating	the	UAS	in	a	tightly	co ntrolled	area	where	only	people	and	property

owners	or	official	representatives	who	have	signed	waivers	will	be	allowed	does	not engender	the	type	of	risks	that	Section	91.151(a)	was	intended	to	alleviate	given	the size	and	speed	of	the	small	UAS.	The	appl icant	believes	that	an	equivalent	level	of safety	can	be	achieved	by	limiting	flights	to	30	m inutes	or	25%	of	battery	power

— whichever	happens	first.	This	restriction	would	be	more	than	adequate	to	return	the UAS	to	its	planned	landing	zone	from	anywhere	in its	limited	operating	area.

1 4	C.F.R.	§91.203(a)&(b) Civil	aircraft:	Certifications	required

. The	regulation provides	in	pertinent	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
curre nt	airworthiness	certificate...”	and	“ (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. ”	Fully	loaded,	the	UAS wei ghs well	under	the	proposed	55

- lb limit	and	is	operated	without	an	on	board	pilot.	As such,	there	is	no	ability	or	place	to	carry	certification	and	registration	documents	or to	display	them	on	the	UAS.	An	equivalent	level	of	safety	will	be	achieved	by	keeping these	documents	at	the	ground	control	point	where	the PIC flying	the	UAS	will	have immediate	access	to	them,	to	the	extent	they	are	applicable	to	the	UA S.

14 CFR	§91.405(a) Maintenance	required

. §91.407(a) (1) Operation	after maintenance,	preventive	maintenance,	rebuilding,	or	alteration .	§91.409(a) (2) Inspections.	§91.417(a)& (b) Maintenance	records.	These	regulations	require	that	an aircraft	operator	or owner	“ S hall	have	that	aircraft	inspected	as	prescribed	in subpart	E	of	this	part	and	shall	between	required	inspections,	except	as	provided	in paragraph	(c)	of	this	section,	have	discrepancies	repaired	as	prescribed	in	part	43	of this	chapter...”	and	that	o thers	shall	inspect	and/or	maintain	the	aircraft	in compliance	with	Part	43. Given	that these	sections	and	Part	43	apply	only	to	aircraft with	an	airworthiness	certificate,	these	sections	do not	apply	to	the	applicant

. T he operator will	perform	maintenance pursuant	to	the	flight	manual	and	operatinghandbook.	An	equivalent	level	of	safety	will	be	achieved	because	the	UAS	is	very

limited	in	size,	would	carry	a	small	payload,	and	would	operate	only	in	restricted areas	for	a	limited	time	period. The	UAS	would be	operating	from	a	level	no	higher than	400	feet	AGL	and could make	an	immediate	landing	if	necessary.	In	addition, the	operator would ensure	that	the	UAS	is	in	working	order	prior	to	initiating	flight, perform	required	maintenance,	and	keep	a	log	of	any maintenance	performed. Because	the	operator	is	most	familiar	with	the	aircraft,	this	person	is	best	suited	to maintain	it	in	an	airworthy	condition.	An	equivalent	level	of	safety	will	be	achieved because	the	operator	will	perform	maintenance	and	inspection s in	accordance	with the	UAS manufacturer’s	User	M a nual.	As	provided	in	the	FOM ,	the	operator	would ensure	that	the	UAS	is	in	working	order	prior	to initiating	flight and	perform required	maintenance needed

. **Additional	Information** The	applicant, Wayne M. Lane,	believes	this	exemption	request	and	associated safety	considerations	adequately	satisfy	the	criteria	provided	in	Section	333	of	the Reform	Act	of	2012,	providing	sufficient	justification	for	the	granting	of	commercial op erations	of	the	applicant’s	UA S	and requests	your	respective	approval	of	this Section	333	exemption	petition	request.
Thank	you	for	your	attention	to	this	matter	and	interest	in this	request.	Please	notify
me of	your	actions	and/or	approvals.
Sincerely,

Wayne M. Lane 7319 Bridlespur	Lane Delaware,	OH	43015