Michael D Crider

Michael Crider Aerial Photography

6141 E agle P oint Lane

Frisco, T X 75034

June 1 6

, 2015

U.S. Department of Transportation

Docket Management System 1200

New Jersey Ave., SE Washington DC 20590

Re: Exemption R eques t Pursuant to S ection 333 of th e F AA R eform A c t and P art 11 o f th e F ederal Aviation

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14

CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR

91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

To wh om it may concern:

Pursuant t o S ection 3 33 o f the F AA M odernization a nd R eform A ct of 2012 a nd 1 4 C FR Part 1 1, Michael D

Crider

, o perato r of small Unmanned A erial S ystems ( UAS), h ereby ap plies f or an e xemption fr om t he listed

Federal Aviation Regulations t o allow c ommerc ial operation o f a small UAS, so l ong as s uch operations are

conducted within a nd u nder t he c onditions o utlined h erein or a s m a y b e established b y t he F AA a s required by

Section 333.

Commerc ial operation s mall UAS, as d escribed h erein, w hich are e quipped w ith cameras an d s ensors, would

operate in t he f ollowing manner:

1. A erial photography and/or video for public and/or private use including real estate, architecture, land

Surveying , engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public events, and

cinematography.

3. Aerial inspection/photography of residential/commercial structures under contract with the owners or

local government authority.

4. Aerial video/photography or providing live video feed to assist with search and rescue operations in

cases of an emergency or natural disaster only when the local authorities or government has requested

it by contract or donation.

As described fully below, the requested exemption would permit the operation of small UAS under controlled

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety

enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of

this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA

Administrat or’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in

t he national airspace system.”

1The n ame, p hone, email a nd a ddress of t he applicant:

Name: Michael D. Crider

Phone: ( 509 ) 209

- 1438

Email: jetstar737 @gmail.com

Address: 6141 E agle P oint Lane, F risco, TX 7 5034 USA

Regulations fro m which t he e xemption is requested:

14 C FR P art 21 s ubpart H

14 CFR 4 5.23 (b)

14 CFR 9 1.7 (a)

14 CFR 9 1.9 ( b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 9 1.151 (a)

14 CFR 9 1.203 ( a) & (b)

14 CFR 9 1.405 (a)

14 CFR 9 1.407 ( a) (1)

14 CFR 9 1.409 ( a) (2)

14 CFR 9 1.417 ( a) & (b)

The s mall UAS’s I w ill be usin g are m ulti

- roto r craft weighing n o m ore than 5 5lbs. i ncluding p ayload. Under

normal conditions they operate at speeds of no m ore than 45 Mph or 39 Knots a nd have the ability hover and

move alo ng a v ertical an d horizontal plane s imultaneously. They w ill operate in l ine o f sight o nly an d b y the

exempted p erson or o the r fully q ualified d esignated p ilot obeying all other loc al and fe deral laws.

Given the s mall s ize o f

t he small U AS and t he controlled e nvironment p rovided t he p roposed operations will

adhere to the Reform A ct’s safety re quir ements. The approval of this ap plication presents no national

security i ssues. Regarding the l evel of s afety s urrounding the p roposed operations a nd t he p ublic benefit,

reduction in e nvironmental impacts, including but not limited to r educed emissions and n oise, t he grant of

the requested exemption i s i n th e public i nterest. A ccordingly th e a pplicant requests that the FAA g rant the

requested exe mption wi th m inimum delay.

Qualifications o f Michael D

. C rider

, CEO an d C hief P ilot o f Michae l Crid er Aerial Photography.

A irline Transport Pilot Certificate N umber 2089380

Airplane Multiengine Land

Rotorcraft Helicopter

B- 737, BH

- 222, CE

- 500, L

- 1329

To tal Time 20,200 hours

Current in the B

- 737 300, 500, 700, 800

RC aircraft 400 hoursAIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will

further enhance the safety of the persons and/or property over using conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial

o perations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The small UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum flight time for ea ch operational flight will be 30 minutes. Flights will be terminated at 25%

battery power reserve or 30 minutes of flight time whichever occurs first.

4. Flights will be operated at an altitude of no more than 400 feet Above Ground L evel (AGL) and not more

than 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the small UAS Pilot in Command (PIC), the Visual

Observer (VO) when needed and may include but not limited to a Camera Operator.

6. The small UAS pilot will be Michael D. Crider or possibly another designated and trained FAA rated

commercial pilot.

7. A briefing will be performed regarding the planned small UAS operations prior to each day’s flight

consisting of all the days’ production activities.

8. The PIC will obtain verbal/written consent of all persons involved with the planned operation and ensure

that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may

be reduced to 30 feet based upon an equivalent level of safety determination, as required under the

FOM. With the advanced permission or direction of the FSDO, operations at closer range may be

approved.

9. The PIC and VO will have been trained in operation of small UAS and receive up

- to

- date information for

the particular small UAS to be operated and will be able to show upon request their competent ability to

operate the small UAS and/or Camera.

10. The PIC and VO will be abl e to c ommunicate by voice at all times.

11. 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 when needed.

12. If the small UAS loses communications or loses GPS signal, the small UAS will have the capability to

return to a pre

- determined location within a designated location and land autonomously.

13. The small UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or

emergencies.

314 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of

airworthiness certificates as required by FAR §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 Subpart H meets the

requirements of an equivalent level of safe ty under Part 11 and Section 333 of the Reform Act. The Federal

Aviation Act (49 U.S.C.§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 small UAS. In all cases, an analysis of

these criteria demonstrates that the small UAS operated without an airworthiness certificate, in the restri cted

environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft

(fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions

proposed.

The small UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither 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 both 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 certificates issued under 14 C.F.R. Part 21, Subpart

H. L astly, application of these same criteria demonstrates that there is no credible threat to national security

posed by the small UAS, d ue 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 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks inclu de 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, the words "limited," "restricted," "light

- sport,"

"experimental," or "provisional," as applicable.

Even though the small UAS will have no airworthiness certificate, an exemption may be needed as the small 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 small UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on

the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the small

UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the

small UAS will see the identification of the small UAS as “Experimental.”

414 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in 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. Given the size of the aircraft for maintenance and use of safety

checklists prior to each flight an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 ( b) (2) provides: 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 small UAS, given its size and configuration has no ability or place to carry such a

flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or

capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the

flight manual at the ground control point where the pilot flying the s mall UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight.

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The

OPERATOR will take all actions including reviewing weather, flight battery requirements, landing and takeoff

distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 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. Small UAS and remotely piloted

aircraft, by their design do not have fully functional dual controls. Flight control 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

instruction in experimental aircraft. The equivalent level of safety 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.

514 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be

operated at less than the minimums prescribed, provided the person operating the helicopter complies with any

route or altitudes prescribed for helicopters by the FAA. As this exemption is for a small UAS that is a helicopter

and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an

elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set

forth herein, the small UAS will never operate at higher than 400 AGL with the exception that in circumstances

where the small UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the small

UAS will not be operated more than 100' above the hig hest point on the structure. It will however be operated

in a restricted area with security perimeter, where buildings and people will not be exposed to operations

without their pre

- obtained consent. The equivalent level of safety will be achieved given th e size, weight, speed

of the small UAS as well as the location where it is operated. No flight will be taken without the permission of

the property owner or local officials. Because of the advance notice to the property owner and participants in

the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight

operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack

of flammable fuel, any risk associated wi th these operations is far less than those presently presented with

conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the small UAS

will ensure separation between these small

- UAS operations and the operations 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 crui sing altitude by reference to an

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available

before departure.” As the small UAS may not have a barometric altimeter, but instead a GPS altitude read out,

an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the

safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS

altitude indicator before flight.

1 4 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) During the day, to fly after that for at least 30 minutes; or (2)

At night, to fly after that f or at least 45 minutes.” The battery powering the small UAS provides approximately 30

minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, small UAS flights

would be limited to approximately 10 minutes in length. Given th e limitations on the small UAS ’s proposed flight

area and the location of its proposed operations within a predetermined area, a longer time frame for flight in

daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a)

falls within the scope of prior exemptions. Operating the small UAS, in a tightly controlled area where only

people and property owners or official representatives who have signed waivers will be allowed, with less than

30 minutes of reserv e fuel, 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. Additionally, limiting small UAS flights to 10 minutes would greatly

6reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety

can be achieved by limiting flights to 30 minutes or 25% of battery power

— whichever happens first. This

restriction would be more than adequate to return the small UAS to its planned landing zone from anywhere in

its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 9 1.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate. . .

. (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.

The small UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pil ot. As such, there

is no ability or place to carry certification and registration documents or to display them on the small UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the

pilot flying t he small UAS will have immediate access to them; to the extent they are applicable to the small UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner “shall 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 r epaire d as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the

aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an

airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the

operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved

because these small UASs are very limited in size and will carry a small payload and operate only in restricted

areas for limited periods of time. If mechanical issues arise the small UAS can land immediately and will be

operating from no higher than 400 feet AGL. The operator will ensure that the small UAS is in working order

prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed.

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in

an airworthy condition to provide the eq uivalent level of safety.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in

accordance with the small UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM).

As provided in th e FOM, the operator will ensure that the small UAS is in working order prior to initiating flight

and perform required maintenance needed.

7Small UAS Information

Small UAS ’s to be used are as follows but not limited to providing they are within the scope of the exemption

granted by the FAA:

1. 3D Robotics Solo Quad C opter

• Weight (Batt ery & Propellers Included)

– 3.3 lbs.

• Autopilot: 3DR Pixhawk2

• Flight Code: A rduPilot Copter

• Control: 3DR Solo Controller

• Wireless Link : 3DR Link 1 .0

• Frequency: 2.4 GHz

• Maximum altitude: 328 ft. (100 m)

• Range: .5 miles

• Payload capacity: 1.1 lbs (500 g)

• Crui se speed 5.7 mph

• Maximum speed: 55 mph

• Maximum climb rate 11 mph ( 5.0 m/s)

• Maximum descent rate: 5.5 mph (2.5 m/s)

• Headwind limitation: 25 mph

• C rosswind limitation 25 mph

• Estimated flight time 25 min

• Camera Gimbal 3DR Solo smart gimbal

• Camera GoPro 4

• Safety fea tures:

o Return to Launch with loss of control link or low battery

o GPS controlled auto takeoff and auto land

o GPS limited maximum altitude (set to 300 feet)

o GPS programmable fence

o Preflight automatic systems check, magnetic interference, gyro calibration, GPS lock,

Battery voltage check.

• Solo Flight Battery : 4s 5300mah.

82. Alware Cyclone X8 Octocopter

• Frame: Made of 3K carbon fiber

• D i agonal Wheelbase: 900mm

.

• Frame Arm Length (with Motor Mount): 455mm

• Frame Weight (With Retract System, Motor, ESC, Props) 3385g

• Retractable Landing Gear

• 8 High Efficiency Motor s

• High Efficiency Carbon Props 14x4.7 inch

• Maximum Takeoff Weight: 19 lbs. ( 8.6 kg)

• 3 Axis Gimbal for Sony NEX 5n C amera

• Power Battery: 6s Lipo (9000 mAh

- 20000m Ah 20C min

• Autopilot 3DR Pixhawk

• Flight Code : A rduPilot Copter

• Wireless Link: FrSky Taranis

• Frequency 2.4Ghz

• Range 1 mile

• Telemetry link: 3DR 900 mhz

• Safety Features:

o Return to Launch with loss of control link or low battery

o GPS auto hover (loiter mode)

o GPS limited maximum altitude (set to 300 feet)

o GPS programmable fence

o Telemetry systems for system health, Battery volt age , Battery mAh used, link quality, GPS

status

, all with voice warnings

.

o X8 octocopter configuration which allows safe landing with motor or prop failure

• Cruise speed : 5mph

• Maximu m speed : 30mph

• Maximum climb rate : 11mph

• Maximum descent rate : 5mph

• Wind limitations: 30mph

• Estimated Flight Time: 15min

Conclusion

Thank you for the consideration of these exemptions.

Sincerely,

Michael Crider

CEO Michael Crider Aerial Photography

9