Cody Anderson

April 28, 2015
20215 12 th Ave NW
Shoreline
, WA 98177
Cell (206) 708 3382 Home (206) 542 4558
Email: andersoncody@ou tlook.com

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

Exemp tion Request Section 333 of the FAA Reform Act of 2012

References: 1) FAA Exemption No. 11 138, Regulatory Docket No. FAA-2014-0481 in

the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

– 2014

– 0508
in the matter of the petition of ADVANCED AVIATION SOLUTIONS
LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in
the matter of the petition of FLYING CAM INC

Dear Sir or Madam,
In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, I Cody Anderson
, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1); 91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration ( FAA) for the purposes of aerial photography, cinematography, videography, mapping, crop surveying, inspections and other flig ht operations that could be performed safely and more cost effectively with the use of small UAS at low
altitude within the U.S. natio nal airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the aut horization and permission of clients or
their authorize d agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted within an d under the
conditions outlined here in or as may be established by the FAA as required by Section 333. The
conditions identified and proposed by the petitioner are drawn from references 1-3.

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;

61.1 13(a) & (b); The petitioner requests re lief in order to facilitate the utilization of pilots, who hold a PRIVATE PILOT (or g reater) certificate. Any pilots operating under this exemption would be required to co mply with any conditions as set forth and in a similar fashion to the previously granted exemptions. 91.119(c) As discussed in Exe mption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the gr ound may require that the UA be operated closer than 500 feet to essential persons, or ob j ec ts that would not be possible without additional relief. The petitioner requests modifi cation, waiver or exemption and clarification concerning the terms “congested area s” and “densely populated”. The petitioner requests waiver for this condition to
all ow reasonable and responsible operations in areas of subdivisions and neighborhoods if required.91.121 As discussed in Exemp tion 11138 (DOUGLAS TRUDEAU) is inapplicable since

the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor
for altitude information. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for man ned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2 689, 5745, and 10650. In addition, similar UAS-specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS prov ides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documen ts contain
a condition in which the PIC will initiate a landing procedure when battery remaining reac hes a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum powe r reserve for flight in daytime VFR
conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1 ) & (2); 91.417(a) & (b) As discussed in
Exe mption 11138 (DOUGLAS TRUDEAU), The pet itioner proposes to inspect and ensure that the UAS is in a condition for safe flight i n accordance with the operating documents. The FAA found that adherence to the petitio ner’s operating documents and the conditions and limitations specified, describing th e requirements for maintenance, inspection, and recordkeeping, were
sufficient to ensure that safety would not be adversely affected.

The UAS

The Quanum Nova is a consumer grade small rotorcraft in the quadcopter configuration with an
ad vertised weight of less than 875g designed primarily to carry aloft a hi gh defini tion camera. It
has an advertised maximum speed of less than 30 knots (15m /s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm) I t utilizes an internal inertial measuring unit (IMU) with integrated barometr ic sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC
certified radio con trol (RC) unit. Real time video information is transmitted back to a grou ndcontrol station allowing the operator and/or PIC camera imagery and control camera angle. It has

failsafe modes of operatio n for either loss of RC or GPS signal. Altitud e can be limited by the
onboard flight cont roller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times t o approximately 15 minutes. The onboard flight controller will warn the pilot
via external lighting and audio cues before r eaching a low battery state. An automatic termination of flight and landing will be initi ated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less t han 10 minutes. T his quadcopter is based on the DJI phantom and shares many characteristics

. More informati on is available at this link, and in the manual ( attachment 1) http://www.hobbyking.com/hobbyking/store/__55108__Quanum_Nova_FPV_GPS_Waypoint_ QuadCopter_w_out_Battery_Mode_2_Ready_to_ Fly_.html?gclid=CjwKEAjw3_ypBRCwoKqK w5P9wgsSJAAbi2K9NSkysI55OVgNVctbHxh94_f5qrL1_FXNz5E_p4clyhoCHJ3w_wcB

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1­3 Conditions and Limitations section and believes that the procedures s pecified therein are reasonable and will be utilized in order to manage and mitigate r isk and ensure public safety. A preflight checklist will be developed and employed to e nsure that the UA airworthiness will be verified before launch.
Airworthiness wil l be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure-prone components.

The petitioner request that in a manner similar t o reference 3, he be allowed to operate within 5 miles of an airport provided that;

“The UA may not operate in Cl ass B, C, or D airspace without written approval from the FAA. The UA ma y not operate within 5 nauti cal miles of the geographic center of a non towered airport as denoted on a current FAA-publi shed
aeronautical chart un less a letter of agreement with that airport’s management is obtained, an d the operation is conducted in accordance with a NOTAM asrequired by the operator’s COA. The letter of agreement with the airport

managemen t must be made available to the Administrator upon request.”

Operations within 5 miles of an airport are not anticipated t o be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operati ons within class B airspace are not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the

e nvironmental impact as compared to similar operations co nducted with manned aircraft of greater proportions, carrying a crew and flammable fue l. Additionally, use of the UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or thei r designees seeking an enhanced perspective for characteristics, amenities, and benefit s of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying appli cations could lead to decreased use of pesticides and fertilizer and conservation
of water as well as increased crop y ields and decreased costs. Aerial surveying and ins pections
can increase work site efficiency, improve volumetric estimations and reduce ris ks. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utiliz ed. Liability insurance will be obtained commensurate with the granting of this req uest for exemption. Flight data including UA flight time, Control Unit operation time, incident, accident, and detai ls concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of thi s application. This data may be submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as required.

ConclusionThe petitioner is requesting this exemption for the purposes of “aerial photography,

cinematography, videography, mapping, crop surveying, inspections and other flight operations”. The reason for such a general and broad based request is that the petitioner wishes to utilize a business strateg y of horizontal i ntegration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time
associa ted with additional exemptions The petitioner's business model is based on the id ea of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effec tive, and legal option to enhance their business or hobby. The petitioner’s

own market research shows pent up demand for these servic es currently exists in the real estate market and other markets are just beginning to emerge. Although videography and phot ography are included in the request, the primary objective will be aerial survey of farm crops for precision agriculture. The petitioner has identified un iversities and other agencies that could benefit from the operation requested in this application. A q uick internet search will show that many are currently operating similar UAS in exactly this fashion without, it is assumed, FAA au thorization. The petitioner has refrained from engaging in commercial use of the UAS. The primary purpose of seeking this exe mption is to obtain the capability to offer th ose services while remaining in co mpliance. The petitioner has 8 years of experience in t he radio control model aircraft hobby

.

Respectfully submitted, Cody Anderson