U

**~S** r Departn1ent ofTransportation, Docket Operations West Building Ground Floor, Room w12B140 1200 New Jersey Avenue, S.E. Washington, DC 20590



### Petition for Exe1nption Under 14 CFR § 

### 11.81 to Allow Commercial Use of Unmanned Aircraft Systems

Petitioner: Minnesota Drone Photography Theodore Knaeble, CEO 621 E 19th Street Minneapolis, MN 55404 Tel.; (507) 384-1856 Email: Theo.Knaeble@gmail.com Website: MNDronePhotography.com

To Whom It May CQncern,

This application is substantiallybased on the FAA's findings in Exemption No. 11351 granted tQ bizUAS Corp on April17, 2015, and exemption number 11977 granted to Wiregrass Aerial Photography on Juiy 6 2015 and in reliance on the analysis provided therein.

1. Sections from which exemptions are sought:Application is hereby made for exemption from;
a. FAA Modernization and ReformActof2012, PL 112-95 FEB.14, 2012, Section 333 b.14 CFR Part 21, subpart H
c. 14 CFR Part 61.113(a) and (b) d. 14 CFT Part 91: i. 91.103(b)(2) ii. 91.105 iij.

**91~109**

. iv.

**91.1~9**



### v.

**91.1~1** vi. 91.151 vii. 91.405

' .l I '• • .' : .,_ 

### .._,.viii. 91.407 ix. 91.409
X. 91.417
2. Reliefsought:
a. Minnesota Drone Photography, wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but notbe limited to) videography, cinematography, photogrammetry, industrial inspections and analyses. This reliefis soughtbecause commercial use ofsUAS is currently prohibited by law unless performed under an exemption. b. This exemption will cover use ofthe following airframes, all ofwhich will weigh less than 55 pounds including payload and energy sources: i. D JI Inspire 1 ii. Other models to be added byfuture amendmenttothis exemption.

3. Public benefit:
a. Use ofsUAS technology to obtain imagery, information and data currently obtained by use ofmanned flight or manual methods: i. Reduces statistical risk to human life dueto manned aircraft accidents (e.g., powerline inspections) and dueto other dangerous activities thatcan be avoided (e.g., scaffolding/rigging failures during stack or bridge inspections). ii. Reduces the costofobtaining such information, which benefits
consumers and the economy. iii. Reduces environmental impactby eliminating sources of hydrocarbon emissions from manned aircraft.

4. Safety not adversely affected:
a. Aircraftwill be registered and marked in accordance with Section 

### 44711 and Part4 7 and Part45, Subpart C. b. Aircraftwill comply with maintenance and inspection requirements ofthe manufacturer. All repair and maintenance workwill beconducted or approved byqualified personnel such as those authorized by Robotic Skies (or equivalent), and will require a testflight after such work Records ofall maintenance and repair workwill bekeptin a maintenance log for each aircraft.
c. All flight operations will be conducted by atleasttwo individuals (PIC and observer) who will maintainverbal communication capabilitywith each other at all times during the flight, and whowill remain stationary on the ground during the flight operations:i. A Pilot In Command (PIC) who possess the following credentials: 1. An Airman Certificate issued under 14 CFR 61 (private pilot license) screened b.v the TSA 2. AThird Class medical certificate issued under 14 CFR 67. 3. A bi-annual flight review under 14 CFR 61.56 4. A certificate ofcompetency for UAS issued by UMEX (or equivalent certification). 5. At least 200 cycles and 25 hours offlight experience in a UAS rotorcraft (or UAS fixed-wing in the case offixed-wing flight operations underthis exemption). Such cycles and hours may be gained duringflights under this exemption ifa safe distance is maintained from persons in accordance with 14 CFR 91.119. 6. At least 5 hours offlight experience and 3 takeoffs and landings in make and model beingflown in the prior 90 days. Such cycles and hours maybe gained duringflights under this exemption ifa safe distance is maintained from persons in accordance with 14CFR 91.119. ii. AVisual Observer. iii. A Sensor Operator as necessary. d. All flight operations will be conducted in accordance with valid Certificates ofAuthorization.
e. All flight operations will comply with the following: i. The manufacturers' Aircraft FlightManuals and Oneration Guidelines ii. Wiregrass Aerial Photographyflight operations policies including lost communication and other emergency and safety procedures. iii. Conducted in VMC conditions during daylight hours. iv. PIC and VO will maintain VLOS at all times.
v. Pre-flight inspections (including ground control station, ifany) and safety risk assessments will be conducted priorto each flight vi. Flight altitudes will remain below400 feet above ground level. vii. Flight ground speeds will notexceed 50 knots. viii. Not intrudeinto Class B, CorD airspace, orpublished approach, SID or STAR, ortake place within 5 nautical miles ofan airport ix. Notbe made near persons as required in 14CFR 91.119 and not
over persons on the ground withouttheir prior permission.
x. Each flight will belogged in both thePIC's logbook and the aircraft logbook. xi. Not exceed 75% ofthe battery orfuel capacity ofthe aircraft, or 30 minutes, whichever occurs first.xii. Any incidents will be reported to NTSB within 24 hours of
occurrence. xiii. Minnesota Drone Photography will maintain liability insurance of at least $1,000,000 issued by a major aviation insurance underwriter. xiv. Any applicable local FSDO requirements.
xv. All other applicable regulations concerned with the operation of aircraft. f. Aircraftwill use 2.4 GHz for control ofthe aircraft, and 5.8 GHz for sending data with well-defined and tested lostlink procedures.

Please advise ofany additional information or changes that may be required.

Sincerely,

# ~~. Theodore Knaeble CEO, Minnesota Drone Photography July 7th 2015