Geoffrey P. Armstrong

6617 Peppermill Dr Las Vegas, NV 89146 (702) 5 69 -8975 silverado595@gmail.com

Dear Sir or Mad am:
This petition is being submitted o n my behalf without legal counsel or consulting services.

I am a Commercial, Instrument Rated FAA Helico pter and Airplane Pilot, Certificate # 2932656

Pursuant to Section 3 33 of the FAA Modernizatio n and Reform Act of 201 2 (the Reform Act), and 14 C. F.R. Part 11, Geoffrey P. Armstrong , a n FAA rated Helicopter and Airplane Commercial Instrument Pilot and freelance multimedia producer , hereby applies for an exemp tion from the Federal Aviation Regulations (FARs) listed belo w to allow op eration of ou r Small Unmanned Aircraft System (sUAS) co mmercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlin ed herein o r as may be estab lished b y th e FAA as required by Section 333.

The requested exemption would permit Geoffrey P. Armstrong to pursue h is commercial interests in providing services to clien ts using a small advanced sUAV in the fo llowing areas: Real Estate, Marketing, Lan d Man agemen t/ Surveying, and Special Events

. Geoffrey P. Armstrong states that all sUAS flights will occur over private or
contro lled access prop erty and w ill do so with the property owner's consent and kn owledge and that on ly people who have consented or otherwise have ag re ed to be w ithin th e UAS’ radius during filming and photograph y application s.
Geoffrey P. A rmstrong has demonstrated the ability to safely and effectively fly the sUAS DJI S900 which will be used for all commercial and private purposes. Geoffrey P. Armstrong c om plies with local ordinances an d l aws regarding t he operation of sUAS , and adheres to all weather and e nvironmental restrictions or limitations in reference to the operations of sUAS.

All flights will occur in ordinan ce with an y state or local laws regar ding privacy.

I, Geoffrey P. Armstrong , am seeking the exemption becau se I am committed to complying with all o f the rules,
gu idelines , limitations, and future legislation set forth by the FAA. I agree to operate th e sUAS in the manner that I have described, an d for the pu rposes that I have described. With out the exemption r equest granted, I w ould be

un able to safely an d effectively run my busin ess, and it is my intention to comply with the FA A an d obtain an exemption o f the following regulation s.

The follow ing contains my list of reg ulations from which I am seeking exemption, and a complete list of
respo nsibilities I assume as o perator; it also contains inform ation r egarding the aircraft, public b enefit and safety features, a nd similar petitions requests gran ted.

**Regulations from**  **which exemption is requested:** 

14 C.F.R. Part 21 14 C. F.R. 45.23(b) 14 C.F.R. 6 1. 11 3(a) & (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. 91.11914 C.F.R. 91.121

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

**I, THE OPERATOR ,**  **ASSUME THE FOLLOWING RESPONSIBILITIES** 1. Operations authorized by this grant of exemption are limited to the DJI S900 w eighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to am end this exemption. 2. Opera tions for the purpose of closed -s et motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determ ine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses , as specified on the PIC’s FAA -i ssued airm an medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated w ithin the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC alw ays maintains VLOS capability. The VO and PIC must be able to c ommunicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designat ed 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 duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operat ions in accordance w ith the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operation s and made available to the Administrator upon request. If a discrepancy exists between the conditions and 4 limitations in this exemption and the procedures

ou tlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must fol low the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enfo rcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS −80) may be contacted if questions arise regarding updates or r evisions to the operating documents. 8. Any UAS tha t has undergone 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 prior to conducting further operations under this exemption. Functio nal test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is resp onsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for

safe flight. The pre

- flight inspectio n must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance ha s been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 5 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and

em ergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this e xemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. 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). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operat e within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted w ith an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical char t, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcemen t official upon request. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or w hen visibility is less than 3 statute miles from the PIC. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considerin g wind and forecast weather conditions) there is enough available pow er for the UA to conduct the intended operation and to operate after that for at least five minutes or w ith the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted un der the terms of the attached COA. 6 22. All aircraft operated in accordance w ith this exemption must be identified by serial number, registered in accordance w ith 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. 23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control St ation of the UAS any timethe aircraft is operating. These documents must be made available to the Administrator or any law enforcement

official upon request. 24. The UA must remain clear and give wa y to all manned aviation operations and activities at al l times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures ar e 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 le ave such protection and are w ithin 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for opera ting closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonpartic ipating persons under this exemption. 27. All operations shall be conducted over private or controlled

- access property with permission from the property

ow ner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's U AS Integration Office (AFS −80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

**SIMILAR EXEMPTIONS**

They are similar in all/or many material re spects to relief previously requested in Grant of Exemption Nos. 11062
, 11109, 11112, and 11213

**Public Benefit a nd Safety** 

Unmann ed Aircraft System sUAVs are often seen as su perior to helicopters as an aerial video gathering platform due to the smaller devices cheaper equipmen t and personnel co st, reduced noise and as such, a much smaller environ mental impact which p ro motes pu blic safety. Geoffrey Armstrong is petitioning for an exemption to o perate a DJI S900 with a built-i n stabilized HD camera and GPS safety features which limit its ab ility to limit the height it flies above ground lev el (AGL), to limit the radius of the d istance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including a no -f

ly zone feature. The DJI S900 also has a failsafe fu nction that is triggered in the event co mmunication is lo st between the sUAS and the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and land manually

. These specifications meet with the Model Aircraft Operating Sta ndard s as set below:

 The petitioner w ill only operate its sUAS in line

- of

- sight of a pilot and/or observer and will operate at sites that are `sufficient distance' from populated areas w ith in the sterile area described in the FOPM. Such operations will ensure that the sUAS will "not create a hazard to users of the national airspace system or the public." When flying the sUAS within three (3) miles of an airport, airport operators w ill be notified and th e operator w ill

g ive th e righ t -of-wa

y to avo id flying in th e proximity o f fu ll -sc ale aircraft. Maximum fligh t time for each operation will be 30 minutes.

 Flights will be terminated when battery levels reach 25%, allo w ing su fficient reserv e flight time to safely lan d the sUAS.

 The sUAS will be programmed so it will not be op erated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from which videography is planned.

 Minimum crew for each ope ration shall consist of: sUAS pilot, a visual sUAS observer, and the camera operator.

 The sUAS PIC w ill be an FAA licensed airman holding a minimu m of a Private Pilot certificate

.

 The sUAS operated by the petitio ner weighs less than 25 poun ds, including all p ayload (i.e. camera, lens, and stabilized gimbal).

 The sUAS will operate at speeds of no more than 50 knots, can hover, an d can simultan eously move vertically and h orizontally.

 Geoffrey P. Armstrong being a licensed FAA Helicopter and Airplane Commercial In strument rated Pilot will follow and adhere to th e Reform Act's safety requirements.

If you have any question or need additional information, please contact me at silverado595@gmail.com or (702) 569-8975

Thank you Geoffrey Armstrong