**Andrew Maroudas** 954

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6233 Osprey

Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

1 Andrew Maroudas

- Section 333 Exemption Petition May 27, 2015 U. S. Department of Transportation, Docket Operations West Building Ground Floor , Room W12

- 140 1200 New Jersey

Ave., SE Washington, DC 20590

- 0001 Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam: I, Andrew Maroudas, am writing pursuant to the FAA Modernization and Reform Act of 2012 and 14 C. F.R. Part 11 to request an exemption of the above referenced FARs to allow operation of a small ultra

- lightweight unmanned ai rcraft s ys tem (UAS) for commercial purposes in the National Airspace Sy stem (NAS) regulated by the FAA. The applicant, Andrew Maro udas, is a licensed FAA Private Pilot (L icense Number 465894202). As described more full y , the granting of this exemption request would permit the operation of a small UAS for the main purpose of providing low altitude aerial photography /videography

in th e South Florida area to the general public, government, educational groups and to individuals for Real Estate and personal uses. Additionally , we request that we be allowed to use our sy stem to benefit governmental first responders nearb y who might require assistance, including fire fighters, rescue personnel, law enforcement agencies, and federal agencies, et al., while remaining subject to all limitations cited in this application as we do so. Additionally , granting this exemption request would fulfill the Secretary of Transportation's FAA Administrator's responsibilities to "... establish requirements for the safe operation of such aircraft s ys tems in the National Airspace S ys tem" under Section 333(c) of the Reform Act.**Andrew Maroudas** 954

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Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

2 **I. Contact Information:** Andrew Maroudas 6233 Osprey

Ter Coconut Creek, FL 33073 954

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- 0591 amaroudas@hotmail.com **II. Regulations from which exemption is requested:** 14 CFR Part 21, 14 CFR 45.23(b), 14 CFR 6 1.113(a); 61.113(b), 14 CF R 91.7(a); 91.9(b)(2); 91.103(b), 14 CFR 91.109; 91.119; 91.12l, 14 CFR 91.151(a); 91.203(a) & (b), 14 CFR Subpart E (91.405(a); 91.407 (a)(l), 14 CFR Subpart E (91.409(a)(2); 91 .417(a) & (b)), and FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)( l ) (See addendum) **III . Extent of Relief and Reason:**  I am asking for the FAA to grant the amount of relief from each regulation as is deemed appropriate for the safe operation of the small UAS and inclusion into the NAS. The reason for the exemption request is because it is currentl y unlawful to fly UAS's in the NAS for commercial purposes thereb y den yi ng the general public the advantages associated with their use. **IV. Benefit to the Public as a Whole:** Aerial photograph y

/videography

has been around for a long time through manned fixed wing aircraft and helicopters. Manned fixed wing aircraft and helicopters are expensive to operate and to hire. Man y people and businesses cannot afford the high cost of manned aircraft pho tograph y/videography

. UAS operations allow for people and businesses to be able to utilize aerial photography

/videography

under a much smaller budget. Low

- level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics of large, complex properties with several buildings and large trees. The benefits of reduced cost and improved quality of presentation from the U A will be valuable to and benefit man y buye rs and sellers of real property. Congress has already proclaimed that it is in the public's interest to integrate commercially flown UAS's into the national airspace s ys tem, hence the passing of the Reform Act. The lightweight UAS is battery

powered and creates no emissions that can harm the environment. The consequences of an ultra

- light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heav y, contain combustible fuel and can cause catastrophic devastation to the public.**Andrew Maroudas** 954

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Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

3 **V. This Exemption would increase safety due to the fact that all Flight Safety and**  **Operational requirements as designated by the FAA**  **will be complied with.** The UA, powered b y batteries, is smaller, lighter, requires no fuel, and is more maneuverable than larger aircr aft running on combustible fuel. It operates at lower altitudes with no people on board , and will thereby

reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodil y injury . With a small payload and maximum fli ght time of only 25 minutes , with maximum air speed of 30 knots, this offers little or no risk to national security.
1) Operations will be conducted using DJ I Phantom 2 VI SI ON. • A lightweight (maximum gross weight of 3 pounds), electric motors powered by batteries and operated with four rotors in the form of a quad

- copter that takes off and lands v erticall y, manufactured b y DJ I. • An on

- board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground

- based transmitter/controller; • A stock DJ I digital camera capable of capturing imagery in the form of full color, high definition still photos and video; • A stock DJ I on - board telemetry s ys tem that delivers flight data from the on

- board flight computer to the stock DJI on - board radio transmitter including altitude AGL, airspeed , compass direction of flight and direction back to its launch site; • A stock DJ I on - board radio transmitter that transmits live video from the on

- board camera plus all the flight data from the telemetry s ys tem described above; 2) The UA may

not be flown at an indicated airspeed exceeding 30 knots. 3) The UA must be operated at an altitude of no more than 300 feet above ground level (AGL), as indicated b y the procedures specifi ed in the operating documents. All altitudes reported to ATC must be in feet AGL. 4) The UA must be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times. This requires the PI C to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA

- issued airman medical certificate. 5) All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the VO at all times. The VO may be used to satisfy

the VLOS requirement as long as the PI C alway s maintains VLOS capability . The VO and PI C must be able to communicate verbally at all times. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating documents.**Andrew Maroudas** 954

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Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

4 6) The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may

update or revise its op erating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if he petitions for extension or amendm ent to the grant of exemption. I f the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. 7) Prior to each flight, the PI C must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records. 8) An y UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 9) The pre

- flight inspection sect ion in the operating documents must account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 10) The operator must follow the UAS manufacturer's aircraft/compo nent, maintenance, overhaul, replacement, inspection, and life limit requirements. 11) The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service. 12) Each UAS operated under the exemption must comply with all manufacturer Safety Bulletins. 13) The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 14) UAS operations must be conducted b y a PI C possessing at least a private pi lot certificate and at least a current third

- class medical certificate. The PI C must also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.**Andrew Maroudas** 954

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Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

5 15) Prior to operations condu cted for the purpose of aerial photograph y/videography and augmenting real estate listing videos (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS ro torcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience

- buil ding flights can also be conducted under the grant of exemption to accomplish the required flight time. However, said training operations may

only be conducted during dedicated training sessions. During training, proficiency , and experience

- building flight s the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 91.119. 16) Prior to operations conducted for the purpose of aerial photograph y/videography and augmenting real estate listing videos (or similar operations), the PI C must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations under the exemption; 5 hours make and model time may be included in the 1 0 hours of multi

- rotor time prescribed above. The PI C must accomplish 3 take

- offs and landings in the preceding 90 day s (for currency purposes). Training, proficiency , experience

- building, and take

- off and landing currency flights can be conducted under th is grant of exemption to accomplish the required flight time and 90 day currency . However, said training operations may only be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 91.119. 17) The operator may

not permit the PI C to operate the UAS for the purpose of aerial photograph y/videography and augmenting real estate listing videos (or similar operations), unless the PI C has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maint aining appropriate distances from people, vessels, vehicles and structures. 18} UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be conducted under visual meteorological conditions (VMC}. 19) The UA may

not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart. 20) The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less th an 3 statute miles from the PI C. 21) If the UA loses communications or loses its GPS signal, it must return to a pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents. 22) The PI C mu st abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.**Andrew Maroudas** 954

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6 23) The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining. 24) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 25) AII aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 26) Before conducting operations, the ra dio frequency spectrum used for operation and control of the UA must comply

with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 27) The documents required under 14 CFR 91.9 and 91.203 must be ava ilable to the PI C at the Ground Control Station of the UAS an y time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 28) The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 29) The UAS may

not be operated b y the PIC from any moving device or vehicle. 30) The UA may

not be operated over congested or densel y populated areas. 31) Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediatel y and/or; b. The aircraft is operated ne ar vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PI C, VO, operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 32) AII operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.**Andrew Maroudas** 954

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Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

7 33) An y incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. A ccidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Unless otherwise specified in the grant of exemption the UAS, the UAS PIC, and the UAS operations must comply

with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. I am prepared to modify

or amend an y part of this request to satisfy the need for an equivalent level of safety . Please contact me at an y time if yo u require additiona l information or clarification. I look forward to working with your office.
Thank you,

Andrew Maroudas 6233 Osprey

Ter Coconut Creek, FL 33073 954

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- 0591 amaroudas@hotmail.com**Andrew Maroudas** 954

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6233 Osprey

Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

8 **ADDENDUM EXEMPTION REQUESTS**  **AND EQUIVALENT LE V**  **EL OF SAFETY**
I request an exemption from the following regulations as well as any additional regulations that may technicall y appl y to the operation of the UAS Sy stem: 14 CFR Part 21, Subpart H: Airworthiness Certificates 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of ty pe and supplemental ty

pe certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Section 45.23(b) prescribes that 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, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable. Section 61.113(a) and (b) prescribes that (a) no person who holds a private pilot certifi cate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) a private pilot may , for compensation or hire, act as pilot in command of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. Section 91. 7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy condition. Section 91.7 (b) prescribes that the pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe fli ght and that the PI C shall discontinue the flight when un

- airworthy mechanical, electrical, or structural conditions occur.**Andrew Maroudas** 954

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Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

9 Section 91.9(b)(2) prohibits operation of U.S.

- registered civil aircraft unless there is available in the aircraft a current appro ved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Section 91.1 03 (b) prescribes that a pilot shall for any flight, become familiar with runway lengths at airports of intended use, and takeoff and landing distance information.
S ection 91.1 09( a) prescribes, in pertinent part, that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls. Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) An ywh ere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembl y 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 sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. (d) He licopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface (1) A helicopter may

be operated at less than the minimums prescribed in paragraph (b) or (c) of this sect ion, provided each person operating the helicopter complies with any routes or altitudes specificall y prescribed for helicopters b y the FAA; and (2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section. Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set available within 100 NM of the aircraft " ... to the elevation of the d eparture airport or an appropriate altimeter setting available before departure." Section 91.151 (a) prescribes that no person may begin a flight in an airplane under VFR conditions unless there is enough fuel to fl y to the first point of intended landing and, as suming normal cruising speed, ( 1) during the day , to fl y after that for at l east 30 minutes

.**Andrew Maroudas** 954

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Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

10 Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworth iness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Applicat ion as provided for in § 4 7.31 (c). Section 91.203(b) prescribes, i n pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate 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. At a max imum gross weight of 5.3 pounds, the UA is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety

and meet the intent of 91.203, we propose that documents deem ed appropriate for this aircraft b y the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircra ft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter. Section 91.407(a)(l) prohibits , in pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service b y a person authorized under§ 43.7 of the same chapter. Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.
Sec tion 91.417(a) and (b) prescribes, in pertinent part, that (a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alt eration and records of the 1 00

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include (i ) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and**Andrew Maroudas** 954

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11 (iii) The signature, and certificate number of the person approving the aircraft for return to servi ce. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The c urrent inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and s afety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms pre scribed b y§ 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transfer red with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. Concluding, the Phantom 2 Vision aircraft (UA) will not carry persons or property , will not carry fuel, and will only

fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionall y certificated aircraft performing the same missi o n. If an airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 2 1, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety

.**Andrew Maroudas** 954

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Ter , Coconut Creek, FL 33073 amaroudas@hotmail.com

12 The UA is battery

operated , and the maximum duration of flight from a single battery charge is 25 minutes with a 20% reserve. Since the aircraft will never fl y more than 3/4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent inte rpretation with the word "energy ". It is our intention that the PI C perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." T he PI C will ensure that the aircraft is in an airworth y condition p rior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and fir mware for the on

- board computer. All other maintenance will be performed b y the manufacturer or designated repair facility. The PI C will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the ai rcraft, the PIC can ensure an equivalent level of safety. The UA maximum gross weight is 3.0 pounds and the PI C is not on board. Both the PI C and the VO are required to be in VLOS. Given the unlikely event that both the PI C and VO become medically incapa citated while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention. Therefore, requiring the PI C and VO to meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden. The UA will alway s fly

below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above takeoff point is tran smitted via radio from UA on

- board computer to a display screen held by the PIC, providing a constant updated AGL readout. We propose that the minimum medical requirements for the PI C and VO to be in possession of a valid state issued driver's license. A licensed driver is medically qualified to operate a much larger vehicle.