## August 3, 2015

Robb Stan. President, MyitownTv, Inc. 5600 Trail Blvd, Suite 2 Naples, Florida 34108

FAA Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12

- 140 Washington, DC 20590

To whom it may concern, Re: Docket Number FAA

-2015

-0150

Let me start by giving a brief description of myself. I am a 58 year old married man, and I consider myself a professional adult and a responsible member of the community. I am hoping to take piloting an unmanned aerial system beyond the point of hobby and into a professional occupation. I have spent the past 33 years of my life in the field of video production. I am part owner of MyitwonTV Inc., in Naples, FL. MyitownTV is a full service video production company. Our client list includes some of the areas most prestigious businesses and nonprofit organizations. Most of our clientele are long time customers.

Currently

, I am in the process of launching a visitors information network and web site, SW FLTV.

Personally I have purchased a DJI Phantom 3 and have flown it , legally, for many hours and feel very experienced with it. I have permission from several of our local government agencies to take aerial video and photographs of Collier County and Naples amenities and share them on our network and website. Aerial footage of our beaches has been a very popular subject.

So far, all of the aerial images that I have captured have been pro

- bono. I now realize that the quad

-copter has great potential for being a valuable business tool. Besides adding a unique perspective to the videos we produce for the SW FLTV network it would also provide us with an additional production tool to use on our commercial video shoots.

Another industry that would benefit from our aerial video and photography services is the Southwest Florida real estate industry. I have noticed n umerous Realtors are using photos and videos taken with drones in their listings. I believe my company could take their imagery to a whole new level because of my many years of experience in the video production industry. W e could also enhance their videos including stock footage that we accumulate from our SW FLTV network.I have discovered that it is difficult and confusing of doing it profess ionally because the rules

had have not been clear or written. I kept checking back periodically and eventually fou nd my way here. If my company was to receive a grant of exemption, I would be the registered pilot on record. Along with managed contracting services with qualified operators.

If my company is granted an exemption, I will have accumulated many more hours of flight time with the UAS. I will begin the petition for exemption below:

To the Federal Aviation Authority (FAA), I hereby request exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).

I support my request with the following information: I plan to operate a UAS, the DJI Phantom 3, which is comprised of an unmanned aircraft and a transportable ground station. The Phantom 3 is referred to as a quad

-copter with a maximum gross weight of about 1280 g. It is equipped with four rotors that are driven by electric motors powered by a battery . The UA has a maximum airspeed of 16 m/s. The quad has a built in high definition camera. I plan to operate the UA over various areas near Southwest Florida to enhance our tourism videos

, commercial video productions and real estate videos and photographs . I make the following representations of operational enhancements which I propose to abide by to ensure this exemption will provide a level of safety at least equal to existing rules: • I will only operate in reasonably safe environments that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; and • I will conduct extensive preflight inspections and protocols, during which safety carries primary importance. I state that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warrante d and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333). I request an exemption from § 45.23 Marking of the aircraft because his UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, I state that two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, I state that I will mark his UAS in the larg est possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that he or anyone assisting him as a spotter will see the markings. I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. However, I state that as a safety precaution I will perform a preflight inspection of his UAS before each flight as outl ined in my operating documents. UAS Pilot in Command (PIC) I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however I can achieve an equivalent level of safety as achieved by current regulations because m y UAS does not carry any pilots or passengers. Further, I state that, while helpful, a pilot license will not ensure remote control piloting skills. I further indicate that the risks of operating a UAS are far less than the risk levels inherent in the comm ercial activities outlined in 14 CFR part 61, et seq., thus I request an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in command. Regarding UAS operational training, I have flown numerous practice flights in remote areas as a hob byist simulating flights for future commercial use to gain familiarization with thecharacteristics of his UAS’ performance under different temperature and weather conditions.

I have also practiced computerized simulated flights to maintain adequate skills and response reflex time. In a supplemental request to the FAA, I request consideration of a 120 day temporary airman certificate in accordance with § 63.13, to allow time to obtain a private pilot certificate or to allow the FAA time to establish minimum UAS airman certification standards. UAS Operating Parameters I will abide by the following additional operating conditions under this exemption: • operate my UAS below 400 feet and within a radius distance of 1000 feet from the controller to both aid in direct line of sight visual observation; 1 • operate the UAS for 3

- 7 minutes per flight; • land my UAS prior to the manufacturer’s recommended minimum level of battery power; • operate my UAS only with in visual line of sight (VLOS); • use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with th e remote control pilot is lost; • conduct all operations under my own personal and flight safety protocols (including posting a warning sign readi ng: “Attention Aerial Photography in Progress

– Remain Back 150 feet”) contained in the operating documents and will actively analyze flight data and other sources of information to constantly update a nd enhance my safety protocols; • contact respective ai rports if operations will be within 5 miles to advise them of my estimated flight time, flight duration, elevation of flight a nd other pertinent information; • always obtain all necessary perm issions prior to operation; and • have procedures in place to ab ort flights in the event of safety breaches or potential danger. I note that § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert that since there is currently no certificate applicable to my operation, this regul ation is inapplicable. I note that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board his aircraft and given its size, this regulation is inapplicable. I further indicate an equivalent level of safety will be achieved by maintaining a safety/flight manu al with the UAS ground station. I note that § 91.119 prescribes safe altitudes for the operation of civil aircraft, but that it allows helicopters to be operated at lower altitudes in certain conditions. I state that I will not operate his UAS above the altitude of 300 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus “providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. I assert that given the size, weight, maneuverability, and speed of my UAS, an equivalent or higher level of safety will be achieved. I note that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electroni c GPS with a barometric sensor. Public Interest I state that aerial videogra phy and photography for geographical awareness a nd for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. Granting this exemption to myself and my company would allow me to provi de thi s service at a much lower cost. Further, I would like to indicate my small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. I would also like to state that the operation of my UAS will minimize ecological damage and promote economic growth by providing information to companies or individuals doing business in the Southwest Florida region. Conclusion I would like to conclude by saying thank you for your consideration and time reading this petition. This has been a desire of mine since quad copters became available to thepublic. I have only flown as a hobby to not break any laws until with hopes to become

commercial. I see nothing but p ositive coming from it from this new technology. Tourism and real estate are two of Southwest Florida's largest industries

. Our area would benefit from us sharing it's beautiful landscapes and the realtor would have an advantage because of a much clearer view of properties. The consumer gets a better overall look at things. My company would get to share new technologies and be a pioneer in this virtually new field of photography. All along the way, the federal government collects taxes from all of us. The

e conomy benefits with very little risk of accidents and/or damages from these flyovers.

Thank you again. Very respectfully, 

### Robb Stan