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Kelly Williams November 13 , 2015 162 Tesuque Village Rd Santa Fe, NM 87506 Phone (505)

- 913

- 1094
Email: shutterlift@gmail.com

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

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Mad am, 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

, Kelly Williams

, herby apply for an exemption from th e Federal Aviation Regulations listed below so t ha t I

, Kelly
Williams

, may operate UAS commercially in airspace regulated by the Federal Aviation
Administration. Thank you in advance for your consideration.

I

, Kelly Williams

, hold a private pilot’s license ( Certificate number 3255415 ) and hav e over 100 hours logged in full

- size aircraft and have well over 100 hours of recreational and hobby use of my Align m690 Hexacopt er , Wall

- e 550 quad copter and Ranger EX . The love
for a viation and film have invoked my desire to operate s mall unmanned aircraft syst ems commercially in airspace regulated by the Feder al Aviation Administration for the purposes of aerial photography, cinematography, videography, mapping, crop surveying, search and rescue, and inspections that can be performed safely and more cost effect ively
with the use of small UAS. There by I , Kelly William s , request exemption from the following sections of Title 14, Code of Federal Regulations §§

The conditions identified and proposed by the petitioner are drawn from the references
below :

West Coast Aerial Productions

– Exemption No

. 13191 D ocket ID : FAA

- 2015

- 3126 Kyle L. Hughes

– Exemption No . 13177 Docket ID : FAA

- 2015

- 2684 Bryan Cherry

- Exemption No .11405 Docket ID : FAA

- 2015

- 01182

The specific sections of Title 14 of the Code of Federal Regul ations from which Kelly
William s requests exemptions.

 14 CFR 21 subpart H

 14 CFR 61.113 (a) and (b)

 14 CFR 91.7 (a)

 14 CFR 91.9 (b)(2)

 14 CFR 91.109

 14 CFR 91.119

 14 CFR 91.121

 14 CFR 91.151 (a)

 14 CFR 91.203 (a) and (b)

 14 CFR 91.405 (a)

 14 CFR 91.407 (a)(1)

 14 CFR 91.409 (a)(1) and (2)

 14 CFR 91.417 (a) and (b)

Kelly Williams seeks exemption from the above mentioned FARs for the following

reasons:

14 CFR 21 ( H ) : Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the UAS under either or both of the following provisions: 21.191 Experimental ce rtificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, 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 substantia te 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 commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The
aircraft wil l not carry persons or property, will not carry fuel, and will only fly under3

strict operational requirements. Comb ined with the UA’s light weight ( being constructed primari ly of carbon fiber, plastic and foam ), I propose that the UA will
be at least as sa fe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then I request an exemption of 14 CFR Part 21, Subpart H, and the requirement f

or a n airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 61.113 (a) and (b) : Private pilot privileges and limitations The regulation provides that no person that holds a private pilot certificate may act as pilot 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 business or employment if: (1) The flight is only incidental to that b usiness or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

I

, Kelly Williams (PIC of UAS) , have held a private pilot certificate since 2007 ( Certificate number 3255415 ) and will operate the UA solely and with the ut most

ca u tion and safety. I

, Kelly Williams

, will take all I learned when getting my private pilot certificate and apply it to all UAS operations

, following all regulations in place

.

14 CFR 91.7 (a): Civil aircraft airworthiness The regulation states no person may operate a civil aircraft unless it is in an airworthy
condition.

As the UA will not be issued a n airworthiness certificate

, a n exemption should be granted. A ve ry thorough preflight will be conducted prior to any flight by myself, Kelly
Williams ( PIC ). Due to the size, slow speed, low altitude, and short flight times (15min) a close eye can be kept on the condition of the aircraft and components throughout the flight mission

, providing a heightened level of safety.

14 CFR 91.119: Minimum safe altitudes The regulation establishes minimum safe altitudes in which civil aircraft operate. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA.

As this exemption is for a UAS that is a helicopter as well as a airplane and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated plat form from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at4

higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structu re whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will

, however

, be ope rated in a restricted area within a security perimeter

.

A n equivalent level of safety will be achieved given the small size, weight, and speed of the UAS as well as operation location. No UAS will fly without the express permission of the property owner or local officials. Due to the advanced notice and consent o f property owners and participants in the filming/ photographing activities , all individuals will be aware of the plan n ed flight operations. Compared to flight operations wi th aircraft or rotorcraft weigh ing far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the
low

- altitude operations of the UAS will ensure separation betwee n these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR 91.121 : Altimeter settings This regulation requir es each person operating an air craft to maintain proper altimeter settings by setting altimeter to the current reported altimeter settings of a station along
the cru i se rout e or to the elevation of the departure airport

.

The UA will never f

ly above 400 feet AGL allowing no need to maintain crui sing altitudes in order to prevent conflict with other aircraft. The UAS are equipped with barometric

pressure sensors as well as a GPS altitude read out and a n altitude ceiling warnin g system, providing a live feed back to the PIC. This , along with keeping the aircraft within
visual line of site o f PIC , will achieve an equivalent level of safety

.

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions This regulation provides no person m a y begin a flight in an airplane under VFR conditions unless there is enough fuel on board to fly to the firs t point of intended landing and assuming normal cruising speed to fly at least 30 minutes after that.

The multirotor UAS are battery operated and have maximum flight time s of 13 minute s leaving a 20% reserve on a single battery charge. The fixed wing Ranger EX UA has a maximum flight time of 45 min landing with 20% reserves. A live feed of battery voltage to the PIC will allow for constant monitoring of UAS flight battery voltage during flight

. Since the air craft will never fly more than 1⁄2 mile from the point of intend ed landing, a full battery charge at takeoff as well as monitoring battery voltage th r ou gh out the flight, will ensure that the reserve energy requirements are met in the paragraph.5

14 CFR 91.203 (a) and (b): Required certifications This regulation prescribes that no person may operate air craft without the appropriate

air worthiness certificate. Subpa ragraph (b) states that the air worthiness certificate be displayed at the cabin or cockpit entrance so it is legible to th e passengers or crew.

Due to the small size and lack of pilot or crew on board, there would be no ability to carry certification and registration documents or space to display them on the UAS. An equal level of safety will be achieved by keeping these do cuments on the ground with the PIC and crew available for inspection upon request.

14 CFR 91.405 (a)
, 14 CFR 91.407 (a)(1), 14 CFR 91.409 (a)(1) and (2), and 14 CFR 91.417 (a) and (b): These regulations requi re the owner/operator of an air craft have the aircraft inspected

as p rescribed in paragraph (e) of this part

, and sha ll between required inspections ( except as provided in paragraph (c) of this section), have discrepancies repaired as prescribed in part 43 of this chapter and others shall ins pect or maintain the aircraft in compliance with Part 43.

Given these sections and part 43 apply only to aircraft with an airwo rthiness certificate these sections will not apply. Maintenance will be accomplished by Kelly Williams in
accordance with the f

light manual and operating hand books. An equal amount of safety will be achieved due to the small size, limited payloads and operating in appropriately
safe areas with the consent and knowledge of the surrounding people for limi ted amounts of time, in add ition to my intimate knowledge of the UAS and their operation

.

UAS to be used: Align 690: T he Align m690 is a h exacopter configuration VTOL UA consist ing of six rotating
and counter

- rotating props driven by six brushless electric motors . Payload for the Align

m690 is a DSLR camera, gimbal and video down link. Total weight including battery

, camera and gimbal is 15lbs. Maximum flight time is 13 min ute s landing with 20% reserves in the battery and maximum speed 30mph. It utilizes an interna l inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled by a 2.4Ghz FCC certified

14

- channel radio

, manufactured by Futaba

, the l eading manufacture of RC radios, giving the PIC complete control of the aircraft.

In the unlikely event of signal loss from the pilot , t he Align m690 will stop moving in flight and hold posi tion for 10 seconds while attempting to reestablish a connection with the6

pilot. If co nnection is not obtained the UA will initiate a Return To Home ( RTH) ma neuver by lifting up 15 feet, flying back to the takeoff point and land ing safely

. The Align 690 has a live video down link providing a visual of what the cam era sees and providing and over lay of the aircraft ’s flight parameters including altitude (AGL), satellite count, horizontal velocity, vertical velocity

, relative direction of aircraft from takeoff point and battery voltage.

Wall

- e 550 : The Wall

- e 550 is a quadcopter configuration VTOL UA consisting of four rotating and counter

- rotating props driven by four brushless electric motors. Payload for
the Wall

- e 550 is a GoPro camera, gimbal, secondary CCTV camera, and video down link. Total weight including battery camera and gimbal is 7lbs. Maximum flight time is 15 minutes landing with 20% reserves in the battery and a maximum speed of 30mph. It uses X Aircraft Mini X flight computer that utilizes a n internal inertial measuring unit ( IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled by a 2.4 GHz FCC certified 14

- channel radio, manufactured by Futaba. In the unlikely event of signal loss from the pilot
the Wall

- e 550 will stop moving in flight and hold posi tion for 10 seconds while attempting to reestablish a connection with the pilot. If connection is not obtained

, the UAS will initiate a Return To Home (RTH) maneuver by lifting up 25 feet and fly ing back to the takeoff point, landing safely.

The W all

- e 550 has a live video down link providing a visual of what the cam era sees and providing an over lay of the aircraft ’s flight parameters including altitude (AGL), satellite count, hori zontal velocity, vertical velocity, relative direction of aircraft from takeoff point and battery voltage.

Volantex Ranger EX: The Ranger EX is a fixed wing aircraft to be used primarily for aerial surveying of land. The payload for the ranger is a Gopro camera on a gimbal, secon dary
CCTV camera and video down link. Takeoff weight is 6.5 lbs. with a wing span of 77.9 inches, with a max flight time of 45 minutes

, landing with 20% reserves in the battery and max speed of 45 mph. I will use the Eagle Tree Vec tor f l ight computer that utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled by a 2.4 GHz FCC certified 14

- channel radio, manufactured by Futaba. In the unlikely event of signal loss from the pilot

, the Ranger EX will fly ba ck to the point of
takeoff . Once in signal range the pilot can override the fail safe and land the aircraft safely.
The R anger EX has a li ve video down link providing a visual of what the cam era sees and providing an over lay of the aircraft ’s flight parameters including altitude (AGL), satellite count, horizontal velocity, vertical velocity, relative direction of aircraft from takeoff point

a nd battery voltage.7

The Align m690, Wall

- e 550 and Volantex Ranger EX will be operated by myself

, Kelly
Williams

, and will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

Risk mitigation

I

, Kelly Williams

, will follow all current and upcoming rules and regulations regarding UAS provided by the FAA . As a private pilot my self and the son of a n ATP commercial pilot with

a CFII

, I know the safety precautions and procedures for flying aircraft and will apply my knowledge and practices to all UA operations

. I will perform a th o rough preflight prior to any takeoff and check not only surface weather conditions

, but space weather conditions
fo r solar activity as well , which can degrade RF r eception and GPS accuracy and will not fly if there is a KP index higher than 5. No Flight operations will occur one hour after sun set or
one hour before sunrise or in densely populated areas

. I f w ind speeds are higher than 15 mph the aircraft will be grounded

. Flights will only take place in VFR conditions with no
less than 3⁄4 mile visibility and will never operate in Class B, C, or D airspace without written approval from the FAA.

Airworthiness will be maintained by performance of routine inspectio ns before and after each flight and by maintaining flight and maintenance logs to record time on failure

- prone components.

Public benefit Aerial photography and videography has been used for decades using helicopters or fix ed

wing aircraft ca r r y ing people and explosive fuel. These methods have limitations and dangers that small UA s do not

, as well as being very expe nsive to operate and hire.

The Align m690, Wall

- e 550 and Volantex Ranger EX are battery

- powered and serve as a safe, efficient, and economical alternative to ma n ned aircraft traditionally used to obtain
aerial imagery . By reducing the amount of large ma n ned aircraft needed to preform aerial acquisitions , an exemption allowing the use of the Align m690, Wall

- e 550 and Vol antex Ranger EX UAS woul d reduce the amount of manned aircraft in the NAS, reduce noise and

air pollution and increase the safety of life and property in the air as well as on the ground.

In addition to being safe and efficient

, the UAS are also a n economical alternative to using
manned aircraft to conduct similar aerial operations. As such operation of the Align m690

, Wall

- e 550 and Volantex Ranger EX will allow United States citizens like my self to8

contribute to the growth of the U.S. economy, spec ifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery

- powered Align m690,
Wall

- e 550 and Volantex Ranger EX UA S i ncorporate technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. In addition

, t he
low operating cost of UAS will allow the opportunity for all business and individuals, small and large to afford the use of aerial services thought not to be obtainable.

By operating the Align 690, W all

- e 550

, Volantex Ranger EX UASs, Individuals such as

my self, Kelly Williams , can remain competitive and profitable, and therefore, contribut ing to growth of the U.S. economy

.

Conclusion This petition for exemption satisfies the criteria articulated in the section 333 of the reform act of 2012 including weight, speed, operating capabilities, proximity to airfields and populated areas, operation within visual line of site and national secur ity, provide
more than ade quate justification to grant the requested exemptions allowing commercial operations of UAS by Kelly Williams in the NAS. I

, Kelly Williams

, hold a private pilot certificate ( Certificate number 3255415 ) a nd a third

- class medical

, and
exercise the ut most safety and concern when operating any aircraft, UAS and manned

, and will be able to provide services to the public in a safe and cost effective manner in compliance with all FAA regulations in place and upcoming. I thank you for you r time and consideration,

Sincerely,

Kelly Williams

Kelly Williams 162 Tesuque Village Rd Santa Fe, NM 87506 Phone (505)

- 913

- 1094
Email: shutterlift@gmail.com