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April 17, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590

Petition of Peter Nugent DBA Dronez Aerial for Exemption Pursuant to Section 333 of the FAA
Modernization and Reform Act of 2012 and the procedures contained in 14 C.F.R. Part 11

.

To Whom It May Concern,

I am writing pursuant to the FAA Modernization and Reform Act of 2012 (the Reform Act) and the procedures contained in 14 C.F.R. Part 11, to request that I, Peter Nugent DBA Dronez Aerial, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) listed below so that I, Peter Nugent DBA Dronez Aerial may
operate my small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) under the conditions and limitations set forth in this
Petition

Peter Nugent DBA Dronez Aerial will be operated under controlled visual flight rules ( VFR ) at low altitude in airspace that is permitted in accordance with the approved Certificate of Authorization (COA). I respectfully submit this request for an exemption because I operate

sUASs. Approval of this exemption would thereby enhance safety and fulfill t he Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.”

Regulations from which the exem ption is requested: 14 CFR § 45.23 (b)

, 14 CFR Part 21

, 14 CFR § 61.3

, 14 CFR § 91.7 (a)

, 14 CFR § 91.9 (b) (2)

, 14 CFR § 91.103 (b)

, 14 CFR § 91.109

, 14 CFR § 91.113, 14 CFR § 91.119

, 14 CFR § 91.121

, 14 CFR § 91.151 (a)

, 14 CFR § 91.203 (a) & (b)

, 14 CFR § 91.205 (b)

, 14 CFR § 91.215

, 14 CFR § 91.405 (a)

, 14 CFR § 407 (a) (1)

, and 14 CFR § 409 (a) (2). The Appendix describes the FARs from which an exemption is requested and summarizes the justification for each requested exemption.

The main use o f this s UAS would be for taking real estate photos and videos . The sUAS systems that I plan to use are the DJI P hantom Vision Plus V 3 .0 ( Model number: PV331 and S/N number: PH645484053) and DJI Phantom Vision Plus V 2 .0 ( Model number : PV331 and S/N2

number: PH645197843) that will be referenced in this document

. The DJI Phantom Vision Plus

V 3.0 is my main sUAS, while my DJI Phantom Vision Plus V 2.0 is my backup sUAS.

The safe operation to the NAS and/or persons and/or property will be kept to a minimum by always flying the s UAS within visual eye contact, less than 400 f ee t above ground level (AGL)

, never exceeding 30 miles per hour, and never directly above persons or public places. The orientation of flights will be such that the pilot in command (PIC) always has a visual on the
sUAS and rear mounted LED flight Indicator. PIC will not operate sUAS less than 500 feet below or less than 2,000 feet horizontally from a cl oud or when visibility is less than 3 statute miles from the PIC. Additional safety features on the DJI P hantom Vision Plus V3.0 and DJI
Phantom Vision Plus V2.0 include, return to home, low voltage, enhanced failsafe along with operating in the less pop u lated 5.8 GHZ frequency range.

Pre

- flight inspections last anywhere from 20

- 30 minutes. PIC check s the battery condition/level
in both the transmitter and s UAS. The binding/link feature will not let the s UAS start if
communication is not established. PIC c heck s to see if the propellers are all balanced and has a kit to ensure they are up to maximum safety standards. PIC check s for power

- lines, antennas

, and other overhead objects before every flight. PIC also closely monitor s weather and wind
condi tions as those are factors for flying. At all times PIC operate the sUAS in an unbroken visual line of sight (VLOS). PIC does not make flights alone; there is a visual observer (VO) who watches the sUAS from the ground from another vantage point and unbr oken VLOS

. PIC
and VO communicate verbally wit h one another during all flights in progress

. PIC a lso do es not fly for more than 30 consecutive minutes without landing and changing the batteries and conducting necessary safety checks. Once the batter y is at 25%, PIC begin s return to ground procedures and never operate s the sUAS below 20% battery. Post

- flight, PIC inspect s the sUAS.

PIC take s excellent care of both of sUASs, and is careful to put them back into their specially

designed carrying cases. PC also never flies at night, within 10 miles to the center of an airport, near a manned aircraft, near agricultural fields, above or around other persons, or in any other place that would deem it harmful to nature, property

, people

, or animals.

If in t he future any parts of either DJI need to under go maintenance or alterations, PIC will perform a functional test flight prior to conducting further flights. Functional test flights will be performed with the VO, will remain at least 500 feet from other people, and will not pose a hazard to persons or property.

The radio frequency of the DJI P hantom Vision Plus V3.0 and DJI Phantom Vision Plus 2.0 are
both in the 5.8 GHZ range

. Maximum take

- off weight less is than 5 pounds.

The PIC will be only myself and I have a minimum of 80 hours flying time with both DJI Phantom Vision Plus V3.0 and DJI Phantom Vision Plus V2.0 models. I test, update, and program all the DJI Phantom firmware on a weekly basis and perf orm weekly check

- ups on both

sUASs.

The intended use of both the DJI Phantom Vision Plus V3.0 and DJI Phantom Vision Plus V2.0, and my main objective, are to supplement my existing photography business for local real estate3

agents in The Berkshires with a erial photography and videography the safest way possible. Other photographers are currently offering aerial photography and have a competitive edge.

Respectfully,

Peter Nugent
DBA Dronez Aerial
9 Leslie Avenue Lanesborough, MA 01237
413.445.57234 Appendix

FAR section Subject Justification 14 CFR § 45.23 (b) Requirement to display registration number on vehicle Insufficient space on vehicle

14 CFR Part 21 Aircraft certification requirements and procedures Designed for manned aircraft;
not suitable for off

- the

- shelf 14 CFR § 61.3 Requirement for pilot
certificate Part 61 requirements designed for manned aircraft, not sUAS; petition describes training for sUAS operator

14 CFR § 61.195 Flight instructor limitations
and qualifications Designed for manned aircraft;
not suitable for off

- the

- shelf

sUAS 14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft;
not suitable for off

- the

- shelf

sUAS 14 CFR § 91.9 (b) (2) Requirement for manual to be
available in the cockpit No one aboard to read manual

14 CFR § 91.103 (b) Requirement for crew
members to be onboard Unmanned vehicle

14 CFR § 91.109 Requirement for dual controls during flight instruction No one aboard to operate
controls

14 CFR § 91.113 Right

- of

- way rules: Except water operations A ll flights will be operated within VLOS of the pilot in command (PIC) and visual observer (VO) 14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation
below these altitudes 14 CFR § 91.121 Altimeter settings No one aboard to read
altimeter 14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 14 CFR § 91.203 (a) & (b) Requirement for registration
and airworthiness certificates
to be onboard No one aboard to read
certificates

14 CFR § 91.2 05 (b) Cockpit instruments requirement No one aboard to read
instruments 14 CFR § 91.215 Transponder requirement Vehicle has insufficient useful load; will be operated below ATC radar coverage 14 CFR § 91.405 (a) Inspection requirements Designed for manned aircraft;
not suitable for off

- the

- shelf

sUAS 14 CFR § 91.407 (a) (1) Inspection approval requirements Designed for manned aircraft;
not suitable for off

- the

- shelf

sUAS5

14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft;
not suitable for off

- the

- shelf

sUAS