July 28, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 **RE: Petition of Ae**  **rial World View for Exemption Pursuant to Section 333 of the**  **FAA Reform A** **ct** Petitioner’

s Name and Address: Aerial World View Owner: Hikmet Tekce 29 Webster Hill Blvd West Hartford, CT 06109 860

-888

- 9834 info@aerialworldview.com To whom it may concern: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Aerial World View, operator of Small Unmanned Aircraft Systems (“ UAS s”) equipped to conduct aerial photography and videography, hereby applies for an exemption from the listed Federal Aviation Regulations (“FAR s” ) to allow commercial operation of its UAS s, so long as such operations are conducted within and under the conditions outline d herein or as may be established by the FAA as required by Section 333.1 As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive UAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Aerial World View to conduct commercial operations of UAS s meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333. Aerial World View is a media/technology company co - owned and operated by Hikmet Tekce

. The purpose of Aerial World View is t o develop commerce in the Connecticut area. Mr. Tekce has over 30 years in Remote Controlled (“RC”) aircraft experience in both fixed wing and rotary aircraft. This experience includes development, building, testing and flying a variety of RC aircraft. Mr. Tekce also has over 10,000 hours of simulated flight experience in a variety of passenger aircrafts, and is in the process of obtaining his private pilot license, which is anticipated in September, 2015 . Finally, Mr. Tekce is co -owner of an aviation comp any, specializing in Aircraft Management, Private

-Jet Charter, Aircraft Brokerage and Aviation Consultancy.Aerial World View plans to use the capabilities of UAS s to offer a multitude of services,

including:

- Real Estate Photography and presentation

- Construction site inspections and monitoring

- Event Photography/Videography

- Aerial filmmaking and photography

- Aerial surveying of local water supply to the community

- Volunteer search and rescue for local fire and law enforcement officials

- Agricul ture and Livestock monitoring Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems” , provides a mechanism for seeking expedited FAA authorization of safe civil Unmanned Aircraft Systems (UAS) operations in the Natio nal Airspace System (“NAS”). Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b) (1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “ expedited operation authorization” if several factors are met. Petitioner meets all requirements t o permit FAA approval of commercial UAS operations. The name and address of the applicant are:
Name: Aerial World View, LLC Owner: Hikmet Tekce Address: 29 Webster Hill Blvd

West Hartford, CT 06107 Phone: 860 888 9834 Email: info@aerialworldview.com Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b)(2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91. 121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)UAS s are oftentimes seen as superior to helicopters due to the lesser cost of equipment, the

reduction of personnel needed to operat e equipment, reduced noise levels and zero emissions into the environment. In addition to providing cost savings and ha ving little to no impact on the environment, UAS s provide enhanced safety. These factors are beneficial for, and in the best interest of, the public. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. Petitioner is requesting an exemption to enable Aerial World View to operate a DJI Inspire 1 UAS, as well as a DJI Phantom 3. Both of these are upgraded to latest version firmware, equipped with a 3 axis Zenmuse camera gimbal, which uses a High

- Def video camera that can capture up to 4K (4096x2160p) video and 12M pixel photos. Both of these UAS vehicles ha ve a built

- in capability to lim it 1 ) the height it flies above the ground and 2) the radius of the distance it flies from the operator. The DJI Inspire 1 and Phantom 3 also has the failsafe function of the autopilot system, which means, when the communication between the Main Controller and the transmitter is disconnected, the out puts of all command sticks from controller will go to the center position. If the GPS signal is good enough, the system will automatically trigger Return to Home and will land safely. Both of these aircrafts ha ve a total gross weight of less than 7 pounds when fully equipped. A pre

-flight inspection will be performed by the PIC in accordan ce with the factory instruction manual, as well as redundant checks to include the Internal Measurement Unit (IMU) to make s ure that the compass, gyro and acceleration values are withi n specs, positive GPS locks are secure, battery health in each individual LiPo cells are balanced, and radio signals are locked in. The UAS will be maintained in accordance with the manufacturer’ s instruction manual and only manufacturer's authorized replacement parts will be used.

**FCC Information** The DJI Inspire 1 and Phantom 3 transmitters used for controlling the UAS comply with part 15 of the FCC rules. Operation is subject to the following two conditions : (1) This device may not cause harmful interference, and (2) this device must accept any i nterference received, including interference that may cause undesired operation. The radio transmitters of the DJI Inspire1 and Phantom 3 used for con trolling the UAS is wireless technology which has been tested and found to be compliant with the applicabl e regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency range. **An tenna Separation Distance**  When operating the DJI Inspire 1 or Phantom 3 transmitter, the PIC will maint ain a separation distance of at least 5 cm between his body (excluding fingers, hands, wrists, a nkles and feet) and the antenna to meet RF exposure safety requirements as determined by FCC regulations. **Pilot i n Command and Observer Qualifications and Duties** The PIC will maintain at least a Private Pilot Certificate and a current State issued driver’s

license, plus at least 2 hours flying time and 3 takeoffs and landings within 30 days in the type of UAS utilize d in operations. The PIC will have at least 100 hours total time and at least 30 hours flying Radio Controlled Model Aircraft, of which, 10 hours will be flying UAS s. The PIC is responsible for the safe and efficient operation of the ai rcraft. Specific d uties include all preflight preparation and inspection, in flight operation, post flight requirements, and all procedures including but not limited to:

 Safe in flight operations  Risk evaluation  Current weather conditions for safe flight The Observer must have the visual acuity to observe the UAS and be able to communicate clearly with the PIC. The Observers duties are:

 Warning the PIC of any imp ending obstacles in the flight path of the UAS

.  Warning the PIC of any deviations in the planned flight path of the UAS

.  Warning the PIC should any unauthorized personnel ap pear in the area of the planned flight. The Observer will have the authority t o order the PIC to terminat e the flight should he feel the flight cannot be conducted safely. **General Operating Standards**

• Aerial World View will only operate its UAS in line of sight of a pilot and/or observer and will operate at sites that are a 'suffi cient distance' from populated areas. Such operation will insure that the UAS will "not create a hazard to users of the national airspace system or the public." • Before an operation of a UAS within 5NM of an airport wi th a control tower, the control tower will be called to gain permission to operate the UAS

. The PIC will give the position, altitude and the times the UAV will be operated. The UAS will not be operated at an altitude of over 200 feet AGL. Weather minimums will be 3 m iles visibility and a 1000 foot ceiling.

 Before an operation of a UAS within 5NM of a non

-towe r controlled, airport operators will be notified and the PIC will give the right of way to avoid flying in the proximity of full

- scale aircraft. At no time will the UAS be operated withi n the final app roach course and the takeoff course of any runway. The UAV will not be operated at an altitude of over 200 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.• Maximum flight time for each operational flight will be 18 minutes.

• Flights will be terminated at 30% battery power reserve should that occur prior to the 18 minute limit. • The UAV will be programmed so that it will not be operated at an altitude of more than 200 feet AGL, and not more than 200 feet above an elevated p latform from which filming is planned. • Minimum crew for each operation will consist of the UAS Pilot, and Visual Observer. • The UAV operated by the petitioner weighs less than 5 5 pounds, including the payload (i.e. camera, lens, and gimbals). • The UAS will operate at speeds of no more th an 25 knots, can hover, and can simultaneously move vertically and horizontally. • Given the small size of the UAV and the restricted sterile environment within which they will operate, our UAV operations adhere to the R eform Act's safety requirements.

The UAS, powered by batteries, is smaller, lighter and more ma neuverable than larger aircraft running on combustible fuel. The UAS operates at lower al titudes with no people on board and will thereby reduce current risk levels, enhance safety and d iminish the likelihood of death or serious bodily injury. With a small payload and maximum fligh t time of only 18 minutes, this offers little or no risk to national security. 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 i mproved quality of presentation from the UAS over manned aircraft wi ll be valuable to and ben efit many buyers and sellers of real property, farmers and ranchers, and local city officials to monitor our local water supply. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, p olice, sheriff, etc., all while remaining subject to all limitations cited below: (a) No flight will be made with a Gross weight exceeding 55 pounds; (b) All operations must occur in FAA Class G airspace at no more than 200 feet AGL, at an airspeed of no more than 25 knots and no further than 1600 feet, or 0.263 NM from the PIC; (c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; (d) Operations will be restricted to flights over private prop erty with the permission of the property owner;(e) All required permits will be obtained from state and local government prior to

operation; (f) Aerial World View will not b e operated over densely populated areas; (g) Aerial World View will not be operating over any open

- air assembly of people; (h) Aerial World View will not be operating over heavily trafficked roads; (i) Aerial World View will not be operating at night.
**EXE MPTION REQUESTS A** **ND EQUIVA LENT LEVEL OF SA** **FETY** Aerial World View requests an exemption from the follo wing regulations as well as any additional regulations that may technically apply to the operation of the UAV System: **14 CFR Part 21, A irworthiness Certif** **icates** This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Ae rial Systems, we request an experimental certificate be issued for the DJI Inspi re1 under either or both of the following provisions: 21.191 Experimental certificates. Experimental certificat es are issued for the following purposes: **(a) Research and development** 

. Testing new aircraft design co ncepts, 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 type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for comme rcial p urposes such as market surveys, sales demonstrations, and customer crew training, we wo uld expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict ope rational requirements. Combined with the UAS's light weight, being constructed primarily of carbo n fiber and plastic, we propose that the UAS will be at least as safe, if not safer, than a conve ntionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, a nd the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph. **14 CFR 45.23 Display of marks; general and 45.29 Size of marks.** These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches hig h. Additionally, the aircraft must display the word"EXPERIMENTAL" in letters at least 2 inches high near the ent rance to the cabin, cockpit, or

pilot station. The UAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not ha ve a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word " EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) a nd others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or g reater. Since the aircraft will operate within 0.263 NM of the ground sta tion, the banner s hould be visible to anyone that observes the aircraft and chooses to investigate its point of origin. **14 CFR 61.113 Private pilot privileges and limitations : Pilot in Command and**  **61.133 Commercial pilot privileges and limitations.**  The re gulation provides that no person that holds a Private Pilot certificate may act as P ilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any bus iness o r employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certific ate with a Class III Medi cal issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. **14 CFR 91.7 Prohibits the Operation of an aircraft without an airw** **orthiness certificate**  . As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. **14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements**

. T his regulation provides that no person may operate an airc raft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to e nsure that flight manual information is available to the aircrew while operat in g the aircraft. We request an exemption to this requirement since the aircraft is not only to o small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight, and ready for presentation for any governing official upon request. **14 CFR 91. 109 Flight Instruction; Simulated instrument flight and certain flight**  **tests** The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls . Although the DJI Inspire 1 is capable of duel/linked controls, Aerial World View will be operating with a single remote controller.**91.119 Minimum safe altitudes** :

General. The regulation states that over sparsely populat ed areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the UAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the ite ms listed. Operatio ns will only be flown over property or persons where permission has been obtained and careful preplanned flight path has been performed. The aircraft will be operated at a lo w altitude allowing, if a power unit fails, an emergency landing without undue haz ard to persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. **14 CFR 91.**  **121 A ltimeter settings** 

. The regulation requires that aircraft shall maintain cruisi ng altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The UAS will always fly below 200 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 t he takeoff point is transmitted via radio from the UAS on - board computer to the display scre en held by the PIC, providing a constantly updated AG L readout. **14 CFR 91.151 Fuel requirements for flight in VFR conditions**

. The regulation provides that no person may begin a flig ht in an airplane under day

-VFR conditions unless there is enough fuel to fly to the first point of in tended landing and to fly after that for at least 30 minutes. We feel the intention of this pa ragraph is to provide an energy reserve as a safety buffer for delays to landing. The UAV is battery operated and the maximum duration of flight from a single battery charge is 18 minute s with a 3 0% reserve. Since the aircraft will never fly more than 0.263 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 "fu el" and ask for an equ ivalent interpretation with the word "energy". **14 CFR 91.203(a) & (b) Civil aircraft: Certifications required**

. The regulation provides that an airworthiness certificate, with t he registration number assigned to the aircraft and a reg istration certificate must be abo ard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificat e be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 6.47 pou nds, the UAS is too small to carry documentation, does n ot 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 deemed appropria te for this aircraft by the FAA will be with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the informati on found on airworthiness and registration certificates be permanently affixed t o the airc raft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR45.23.

**14 CFR Subpart E (91.401 -**  **91.417) -**  **Maintenance, Preventive Maintenance, Al**  **terations** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention t hat the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy conditi on pri or to every flight and in addition conduct detailed inspections after every two hours o f flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for t he on

- board computer. All other maintenance will be performed by the manufacturer or their desi gnated repair facility. The PIC will document work performed in accordance with 91.417 . We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. **Safety and Benefits of the UA** **S** Aerial World View will be using the UAS in a variety of applications that generally require expensive full

- size manned aircraft to complete. Small, light, unmanned aerial vehicles offer more efficient and safer benefits over the use of full

- s ized manned aircraft for aerial photography, advanced agriculture monitoring, film and still photo graphy, real estate marketing, ( see attachment 4 ), inspection of buildings and transportation infrastructure, and assistance of first responders in case of emergencies. Replacing significantly larger manned aircraft carrying crew an d flammable fuel with small UAS carrying no passengers or crew creates a much greater margin of safety for the pilots, crew and general public

. By granting Aerial World View‘s requested exemptions, the FAA will help drive development of safe and successful commercial UAS operations and will advanc e the public knowledge base for such operations. Aerial Worl d View is committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by s haring data from its commercial UAS operations and serving as a resource for future UAS researc h operations. Thus, the FAA has good cause t o grant this Petition. **Conclusion** As pointed out in this application, the DJI Inspire1 and Phantom 3, whi ch our company would use, under autho rization by the US DOT

- FAA, are small, light

-weight dev ice s operated within the line of sight of the Pilot

- in

- Com mand (PIC), less than 200 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other loc ation with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized ea ch flight within a radius of this distance.The DJI Inspire1 and Phantom 3 both have been proven capable for controlled flight. Both are a

UAS offered for general sale on the market around the world and have often been used as Model Aircraft in the USA. We are certain that the studies conducted until now by the FAA, about Section 332, Public Law 112

-95, 2014, have already provided you with the assurances on the airworthiness of UAS such as ours. For the foregoing reasons, the exemptions requested herein should be granted and Aerial World View should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA. The submission of this application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some UAS may be used for legitimate commercial activities and under reasonably safe conditions. Signed Hikmet Tekce Aerial World View