# Mattucci Photo graphy

159 Mountain Drive, Carnegie, PA 15106

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey

Avenue, SE Washington, DC 20590 Dear Madam/Sir, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Mattucci Photograph y , seeks an exemption from the Federal Aviation Regulations listed below:  14 C.F.R. 21, subpart H  14 C.F.R. 61.3
- Requir ement for certificates, ratings, and authorizations  14 C.F.R. 61.113(a)&(b) Private pilot privileges and limitations: Pilot in command  14 C.F.R. 61.133(a)

- Commercial pilot privileges and limitations  14 C.F.R. 91.9(b)(2)

- Civil aircraft flight manual, marking, and placard requirements  14 C.F.R. 91.103(b)

– Preflight Actions  14 C.F.R. 91.105

– Flight Crewmember at Stations  14 C.F.R. 91.109(a)

– Flight Instruction  14 C.F.R. 91.119
- Minimum safe altitudes  14 C.F.R. 91.121
- Altimeter settings  14 C.F.R. 91.151(a)

- Fuel requirements for flights in VFR conditions  14 C.F.R. 91.203(a) & (b)

– Civil Aircraft: Certifications Required  14 C.F.R. 91.319(a)(1)  14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417) The requested exemption would authorize Mattucci Photograph y to conduct commercial operations using the DJ I Phantom 3, for aerial data collection, photograph y, video and surveying applications. These applications would primarily consist of low level real estate, building construction and architectural
. Mattucci Photography has been providing these commercial services using manned high

- wing aircraft since 2007. In order to ensure at least an equivalent level of safety to currently

authorized operations using manned aircraft, all operations will be subject to the strict operating requirements defined in the Mattucci Photograph y UAS Flight Operations Manual ( Mattucci Photography requests that the FAA treat the Mattucci Photography UAS Operations Manual as proprietary under 14 C.F.R. 11.3 5(b) and not include this document in the public docket). Additionall y, this petition for exemption is supported by the information contained in the Phantom 3 User Manual, Phantom 3 Pilot Training Guide, and the Smart Flight Battery Safety Guidelines (here after collectivel y referred to as “Manufacturer’s Operations Manuals”). All Mattucci Photography UAS will be operated only by individuals who hold at least an FAA issued private, recreational, or sport pilot certificate and who have successfully complete d Mattucci Photograph y UAS Training Program (the Mattucci Photograph y UAS Training

# Mattucci Photo graphy

159 Mountain Drive, Carnegie, PA 15106 Program document will be submitted separatel y and Mattucci Photograph y requests that the FAA treat this document as proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket). In addition to this document, Mattucci Photograph y will also use the DJ I Phantom manufacturer provided YouTube training videos and manufacturer provided user training manuals. The characteristics of the UAS, detailed UAS operator requirements, and UAS operating parameters given below will ensure that all Mattucci Photograph y UAS operations are carried out with an equivalent or higher level of safety than currentl y authorized manned aircraft operations. The details below re garding Mattucci Photograph y intended UAS applications provide clear evidence that approval of this exemption is in the public interest. **CHARACTERISTICS OF THE UAS** The Phantom 3 series are all very similar UAS. The Phantom 3 is approximately 27 inches a cross, measured diagonally and including the propellers. All are constructed primarily of frangible materials (plastic) and weigh less than 3 pounds each. The Phantom 3 is powered b y a 4480 mAh 4S L iPo battery
. The max flight speed of the Phantom 3 is approximately 36 mph and contain an on

- board GPS and an inertial measurement unit for flight stabilization and automatic failsafe return to home in case of a lost control signal. Additionally , these UAS offer geo

- fencing and max altitude features to r estrict the maximum vertical and horizontal distance the aircraft will fly from its home point. The Phantom 3 and offer the added feature of displaying real time flight data, including battery status, altitude and distance from home, within the DJIApp. The Phantom 3 operated by Mattucci Photography for commercial use will be registered in accordance with 14 C.F.R Part 47, and will be marked in accordance with 14 C.F.R. Part 45, Subpart C, in a size as large as practical for the size of the UA S
. All UA S operated b y Mattucci Photograph y will be maintained in accordance with the manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components and all pertinent instructions in the user manuals. Repairs, component changes, and software/firmware updates will be recorded in the UAS’s maintenance log. Maintenance log entries will include the date, UAS ID number, registration number, current UAS flight time, a description of work performed, and th e name of the individual who completed the work. An y UAS that 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 use in an y commercial operations. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. The PI C who conducts the functional test flight must make an entry in the aircraft records. A pre

fl ight inspection of the UAS will be completed by the PI C prior to each flight operation as specified in the Mattucci Photograph y UAS Operations Manual. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibi ted from operating until the necessary

maintenance has been performed and the UAS is found to be in a condition for safe flight. All Mattucci Photograph y UAS will comply with all applicable manufacturer safet y bulletins.

# Mattucci Photo graphy

159 Mountain Drive, Carnegie, PA 15106 Additional information on the aircraft specifications, performance limitations, operating procedures, and pre

- flight inspections is contained in the attached documents. The safety and reliability of the DJ I Phantom 3 UAS is further supported b y the fact that numerous FAA exemptions have previously been approved for their use in commercial operations. As noted above, the DJ I Phantom 3 is very similar to these UAS and incorporates additional safety features. **UAS OPERATOR REQUIREMENTS** The operating pilot currently has an ATP commercial pilot license and Certified Flight Instructor. FAA certificate #3343137 and #3343137CFI respectivel y, a current 1st class medical, issue date 7/18/2015 and current State of Penns yl vania driver license. Approximately 6300 hours of flight time , 37 years of flying, and over 300 hours of flight time in the past year. In addition, the operating pilot has 8 years of commercial aerial photography experience utilizing high

- wing, single

- engine aircraft platform to conduct the phot o missions. 1 year of drone experience accumulating approximately 50 hours with the DJ I product. **UAS OPERATOR TRAINING REQUIREMENTS** All Mattucci Photography UAS operators will hold at least an FAA issued private, recreational, or sport pilot certificate and will have successfully completed Mattucci Photograph y UAS Training Program. Completion of the Mattucci Photograph y UAS Training Program will ensure safe op erations by not allowing an y P IC to operate a UAS unless that PI C has demonstrated, that he/she is able to safel y operate the UAS in a manner consistent with the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances fro m people, vessels, vehicles and structures. All operators will either meet the flight review requirements specified in 14 CFR **§** 61.56 or will annually

complete and log at least 2 hours of ground instruction with an instructor covering regulations and issue s pertinent to commercial operation of the Phantom 3 UAS. The individual acting as PI C of a UAS will be identified prior to any flight and will not change once the flight has begun. The PI C is the individual in operational control of the flight operation from beginning to end and is responsible for safe flight of the UA. All PI C flight hours used to demonstrate qualifications and currency will be logged in a manner consistent with 14 CFR § 61.51(b). In order to act as PIC, all Mattucci Photograph y UAS op erators will hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory , a possession, or the Federal government. **U AS OPERATING PARAMETERS**  In order to provide for a level of safety at least equivalent to operations conducted using manned aircraft, all Mattucci Photograph y commercial UAS operations will be conducted in accordance with the following s pecific operating limitations:

# Mattucci Photo graphy

159 Mountain Drive, Carnegie, PA 15106

 The UA may not be operated at a speed exceeding 30 knots (34 miles per hour). In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.  All operations shall be conducted in accordance wi th an ATO

- issued COA.

 All UA operations will occur at or below 4 00 ft. AGL or the maximum altitude specified in the COA limitations
. All altitudes must be reported in feet AGL.

 No UA will be operated within 3 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airports not denoted with an ARP, the center of the airport s ymbol as denoted on the current FAA publis hed aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to Mattucci Photograph y . The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

 No UA will be operated within class B, C, D or E airspace unless a letter of agreement from the controlling ATC office is obtained or the flight is otherwise permitted by a COA issued to Mattucci Photograph y . The letter of agreement from ATC must be made available to the Administrator or an y l aw enforcement official upon request.

 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 vi sion unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA
- issued airman medical certificate or U.S. driver’s license.

 All operating documents and a grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations in the grant of exemption take precedence an d must be followed. Otherwise, the PIC must follow the procedures as outlined in the operating documents. Mattucci Photograph y may update or revise its operating documents. However, it is Mattucci Photograph y responsibility to track such revisions and pres ent updated and revised documents to the Administrator or any law enforcement official upon request. Mattucci Photograph y must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If Mattucci Phot ograph y determines that an y update or revision would affect the basis upon which the FAA granted the exemption, then Mattucci Photograph y must petition for an amendment to the grant of exemption.

 UAS operations may

not be conducted during night, as define d 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.

 The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontal ly from a cloud or when visibility is less than 3 statute miles from the PI C.

# Mattucci Photo graphy

159 Mountain Drive, Carnegie, PA 15106

 Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of t he UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. All maintenance and alterations must be properly documented in the aircraft records.

 Any UAS th at 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. The PI C who conducts the functional test flight must make an entry in the aircraft records.

 If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location.

 The PI C must abort the flight in the event of unpredicted obstacles or emergencies.

 The PI C is prohibited from beginning a flight unless the UA’s battery level is at 75% or higher. The PIC must begin returning the UA to the designated landing area when the battery level drops below 25%.

 Documents used b y 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 PI C at the Ground Control Station of the UAS an y time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon re quest.

 The UA must remain clear and give way to all manned aviation operations and activities at all times.

 The UAS may

not be operated b y the PIC from any moving device or vehicle.

 UA will not be operated directly over nonparticipating persons unless b arriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. UA will not be operated over any open - air assembly of people.

 Any incident, accident, or flight operation that tran sgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB ) per instructions contained on the NTSB Web site: www.ntsb.gov.

# Mattucci Photo graphy

159 Mountain Drive, Carnegie, PA 15106 **APPLICATIONS AND PUBLIC INTEREST** The requested exemption would allow Mattucci Photograph y to operate the DJ I Phantom 3 for the purposes of aerial data collection, photograph y, video and surveying applications. These applications would primarily consist of low level real estate, building construction and architectural. Use of UAS for these applications will offer significant advantages related to safet y, time, and cost. Use of manned aircraft in many instances is ty

pically not feasible due to other structures hiding the subject, distance from the subject no close enough to see detail and client’s requests for a lower level perspective. In most cases, use of a UA is quicker and easier than an y other alternative and often yi elds better information. Due to their small size and the fact they carry no fuel, the DJ I Phantom 3 pose s a very low risk of damage to persons or structures on the ground. B ecause these UA are electric powered, they create no harmful emissions and make very little noise. **SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER** Mattucci Photograph y requests the grant of an exemption to the following specific sections of the Title 14 Code of federal Regulations which would allow it to operate micro UAS for commercial use: 14 CFR 21, subpart H, 14 C.F.R Sections 61.3, 61.113(a)&(b), 61.133(a), 91.9 (b)(2), 91 .103(b), 91.105, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407, 91.409, 91.417 **CONCLUSIONS** Mattucci Photograph y respectfully requests that the FAA grant the exemption sought in this request. Mattucci Photography believes that considering the small size and weight of the UAS, along with the UAS PI C training and certification requirements stipulated above and the strict operating guidelines proposed herein, it is clearl y demonstrated that the UAS will be operated s afel y in the national air space (NAS) with an equivalent or greater level of safety compared to manned aircraft. Should an amendment be deemed necessary , w e are prepared to modify or amend any

part of this request b y the FAA to satisfy the need for an eq uivalent level of safety. Please contact us at an y time if you require additional information or clarification. Sincerely , Anthony Mattucci Mattucci Photography 159 Mountain Dr. Carnegie, PA 15106 412
- 719
- 8008 pghaerials@gmail.com

# Mattucci Photo graphy

159 Mountain Drive, Carnegie, PA 15106