Austin Miller

317 County Road 725 E Montrose, IL 62445 aumille@siue.edu 217
- 663
- 6051 U.S. Department of Transportation Docket Operations 1200 New Jersey Ave., SE Washington, DC 20590 August 13, 2015 Submission of Request under Section 333 of the FAA Modernization and Reform Act and Exception under 14 CFR part 21. Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, I Austin Miller request determination by the S ecretary of Transportation giving me the right to conduct commercial UAS for the purposes of: photography, videography, precision agriculture, inspection of infrastructure, mapping and surveying. Following the grant of exemption, I plan to launch my busine ss for providing software stitched images of agricultural landscape to only willing land owners. As well, I will provide images for businesses and private residents. I will be using the Solo which is manufactured by 3D Robotics (3DR). Usage is to be conducted within the limits outlined by the FAA under Section 333. To affect the determination of the exemptions to Section 333(c), I have attached documents that exhibit how I will maintain a level of safety in accordance to those safety regulations already set in place. As well, there are exhibitions of public interest that are involved. In the occurrence that I am granted exemption, the public will gain in the aspects of knowledge on the safety of UAS, receive a service that is more affordable and safer than using a commercial helicopter or plane and receive less disruption in the air above. I will operate UAS that are under 10 pounds, carry no hazardous fuel, create little noise to no pollution, and are fitted with lights for visibility. As well, cost of ope ration is very little comparably to that of manned aircrafts. For these reasons, it is in the public interest that an exemption is granted under FMRA Section 333(c). In the following ways, the public interest will be benefitted:

 The number of injuries and causes of personal property destruction will decrease due to the use of unmanned, nonhazardous fueled UAS.  The environmental damage caused by the exhaust of commercial airplanes and helicopters.  The noise pollution caused by airplanes and helicopters will be reduced due to the low noise signature.  Due to the low cost of operation, the service can be provided at a much more economic price.  The public will gain knowledge on the usage and safety of using UAS.Furthermore, I commit to adding commerce to small towns in the central Illinois region. I greatly

appreciate your consideration and thank you for consideration in granting this exemption.

Austin Miller 317 County Road 725 E Montrose, IL 62445 aumi lle@siue.edu 217
- 663
- 6051**Table of Contents**

I. Regulations
- Requested Exemptions II. Commercial Operation III. Unmanned Aircraft System (UAS) IV. UAS Pilot
- in
- Command (PIC) V. Summary VI. Appendix A
- 3DR Solo Operating Documents VII. Common Documents I. **Regulations -**  **Exemption Requested** Pursuant to 14 C.F.R. and 11.81(e), I, Austin Miller seek exemption from the following regulations and provide proof in why the exemption should be approved on the basis of safety equivalent to that of which th e rules require.

 **14 C.F.R. Part 21 Subpart H -**  **Airworthiness Certificates** o The procedural requirements for issuance of airworthiness certificates as required by 14 C.F.R and 91.203(a)(1) Since the 3DR Solo is of such small stature, exemption from Part 21 Subpart H meets criterion safety level for Part 11 and Section 333 of the FMRA. This is given the size, mass, capability, proximity to airports and largely populated areas of the Solo.

 **14 C.F.R. 45.23(b) -**  **Aircraft Marking and Identification Requirement s**  o 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. My UAS is equipped with lights o n all four arms coming from the body. Also, the registration number with be displayed clearly; therefore, complying with 45.29(f).

 **14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirements** o (b)(2) prohibits operation of U.S.
- registe red civil aircraft 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. I plan to keep all manuals, registration and necessary pap erwork in a binder that I will keep on hand at all times of operation. Thus, meeting levels of safety and precaution. **14 C.F.R. 91.119(c) -**  **Minimum Safe Altitudes** o Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (b) 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 oth er 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. (d) Helicopters, 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 section, provided each person operating the helicopte r complies with any routes or altitudes specifically prescribed for helicopters by the FAA. Operations will be kept below 400 ft. AGL. Given that the Solo has solely a 25 minute charge, it is crucial that the UAS stay w ithin eye sight range and be kept at a reasonable altitude. The UAS also contains a safety feature that does not allow altitude greater than 400 ft. The Solo gives a visual distance and altitude, as well, a return to home feature that brings the UAS direct ly back to the user given GPS coordination. Thus, given the safety features set in place, the UAS meets safety criterion.

 **14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) –**  **Maintenance Inspections** o **91.405(a) States:** Each owner or ope rator of an aircraft
— (a) 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 repaired as prescribed in part 43 of this ch apter o 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless
— (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter o **91.409(a)(2) States:** (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had
— (2) An inspection for the issuance of an airworthiness certificate in accordance wi th part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an ‘‘annu al’’ inspection in the required maintenance records. o **91.417(a) & (b) States:** (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph ( b) of this section: (paragraphs 1 (i
– iii), 2 (i
– vi)); (b) The owner or operator shall retain the following records for the periods prescribed: (paragraphs 1
– 3)An exemption is required because the 3DR Solo does not have an airworthiness certificat e at this time.

However, the utmost safety will be taken into concern before, during and after the flight. Before the flight, a check of systems and functionality will be done. During each flight, any hint of system malfunction will require a recheck of th e UAS. Following each flight will require a check of the propellers and other external problems. I plan to keep a log of any malfunctions and causes of such events. Each check will comply to that of the safety required by this exemption. **II. Commercial Op erator/Operations**  I will be the sole operator of the 3DR Solo. I am a senior pursuing a degree in Mathematics and Statistics at Southern Illinois University Edwardsville with three months of experience flying UAS for recreation. Even though this is not a n extended period of time, I have committed my own money and time into learning to fly my 3DR Solo UAS. I understand the capabilities as well as what the UAS is not capable of doing. My skills lie in the ability to comprehend technology due internship in the field. As well, I have strong situational awareness and am able to see risk factors and avoid them. I acknowledge that I am to follow the above exemption requirements with a strict persistence under the penalty of forfeit of exemptions (and) UAS. **IV Unmanned Aircraft System**  I seek an exemption to operate the 3DR Solo UAS. The Solo is equipped with an autopilot system as well as ground control station software. The UAS will be flown using a combination between the RC controller and the use of a tablet with global positioning system. The solo is a quad
-type UAS with four propellers placed in an X formation. The battery type is a 5200 mAh Lithium
- polymer cell. This means that a max air time of 25 minutes is enforced. As well, given that the battery is be low 15%, it will not take off. The altitude and distance from the user are displayed clearly on the controller. Also, the option to return the UAS to the user can be done at the push of a button. The same can be said about the ability of the UAS to not move from its current position. In the occurrence that the device loses contact with the user, it will return to the position that the controller was last known and hover until connection is gained. At this point, the user can slowly control the 3DR Solo to t he ground in order to check the system. The system also contains a maximum altitude function such that the UAS will not be able to exceed. This will be set at 400 ft at all times. Since the aircraft will be operated within VLOS, it is my belief that operations will be conducted within the safety confinements of Section 91.121 and Section 91.151(b) given the safeguards set in place by 3DR and myself. Given the above information concerning safety hazards including size, weight, speed, operations and ut ilization, an exemption from 14 CFR part 21, subpart H (Airworthiness Certificates) is requested . I am seeking exemption from 45.23 such that the registration number will be in clearly visible lettering.Given that safety inspections will be done reg ularly before and after flights in accordance with the

exemption, I seek exemption from 91.405(a), 91.407(a)(1), 91.417(a)(b). As well, I request exemption from 91.7(a) preventing an aircraft that does not have an airworthiness certificate. Also, 91.9(b) t hat requires an approved flight manual in the aircraft considering the size and load capability of the UAS.
**IV. Public Interest** Growing up in a rural area, I understand the standards of innovation that were necessary in order to grow a farm just like a business. It is necessary to stay several steps ahead of those people in which one is competing with for business. Thus, granting an exemption in my favor will provide a service to the local farmers such that they can see the well
- being of their investmen ts. As well, this creates a learning environment for the community such that they can see how UAS are operated and the level of safety that is required in order to operate such devices. Additionally, I will be providing a service that is more affordable th an helicopters/airplanes, so a wider range of the community can afford the service of aerial photography and videography. Granting my exemption would benefit the public greatly in terms of education, crop production, as well as saving money. **V. Summary** Pursuant to Section 333 of PL 112
-95, Austin A. Miller, apply for authority to conduct commercial use of UAS in the activities of aerial photography, videography, precision agriculture, inspection of infrastructure, mapping and surveying. Exemptions:

 **14 C.F.R. Part 21 Subpart H**  **- Airworthiness Certificates** 

 **14 C.F.R. 45.23(b) -**  **Aircraft Marking and Identification Requirements**

 **14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirements**

 **14 C.F.R. 91.119(c) -**  **Minimum Safe Altitudes**

 **14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) –**  **Maintenance Inspections** During this process, I have exemplified my research as well as my commitment to this exemption. As well, I have shown my range of knowledge on the subject and ho w this exemption will be in the public interest.