August 6, 2015

Tommy N. Turner ThreeD.Space 3278 Deerfield Ct. Williamsburg, VA 23185 (757) 784

- 0979 tommy@threed.space
U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, D.C. 20590 Subject: Exemption Request to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3)(c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.121, 91.203, 91.151 Dear Si r or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I , Tommy N. Turner , a licensed Private Pilot and professional photographer , hereb y applies for an exemption from the Code of Federal Regulations (C. F.R), Federal Aviation Regulations (FARs) identified, to allow commercial operation of lightweight Unmanned Aircraft Sy stems (UAS) for aerial imaging and video. This exemption is made based on information outlined in this petition, to allow commercial oper ation of a DJ I Phantom 3 Professional multi

- rotor equipped with a three

- axis gimbaled camera, DJ I Phantom 2 Vision Plus multi

- rotor equipped with a three

- axis gimbaled camera, and a RF

- 70 fixed wing sUAS equipped with a fixed position multi

spectral camer a , so long as operations are conducted within and under the conditions outlined herein or as may be established b y the Federal Aviation Administration (FAA) as required b y 333. **1. Types of Operations** The requested exemption would permit the operation of small, unmanned multirotor aircraft under controlled conditions to provide the following services to the community ; a. Real Estate photography b. Aerial Survey c. Aerial Photo/video d. Promotional advertising material e. Inspections of real estate properties f. Public entity

support operations g. Precision agriculture aerial surveyingh. Communications infrastructure inspection/monitoring

i. Wildlife and forestry

monitoring j. Pipeline inspection and patrolling k. Construction site inspection and monitoring l. News media coverage This exemption would permit operation of an ultra

- light weight, unmanned (piloted by remote control) in predetermined areas away from the general public, airports, heliports, and vehicular traffic. Operations would be conducted within federal guidelines, by a FAA Licensed Private Pilot with the assistance of an Observer. Operations would be conducted after carefull y reviewing, inspecting, and examining the area of aerial operation to ensure the safety of persons and property. **2. REQUESTED RELIEF**
I am requesting a grant of exemption of the following sections of Title 14 of the Code of Federal Regulations:
1 4 C F R 2 1 ; 1 4 C F R 9 1 , e t s e q ; 1 4 C F R 4 5

. 2 3 (b ) ; 1 4 C F R 6 1

. 1 1 3 ( a) & ( b ) ; 1 4 CFR 407 (a)(1); 1 4 C F R 4 0 9 ( a) ( 2 ) ; 1 4 C F R 4 1 7 ( a) & (b )

. I am also requesting an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations for the following:
1 4 C F R 4 5

. 2 3 (b ) ; 1 4 C F R P art 2 1 ; 1 4 C F R 61.113 (a) & (b); 9 1

. 7 ( a) ; 9 1

. 9 (b ) ( 2 ) ; 9 1

. 1 0 3 (b ) ; 9 1

. 1 1 9 ; 9 1

. 1 2 1 ; 9 1

. 1 5 1 ( a) ; 9 1

. 2 0 3 ( a) & (b ) ; 9 1

. 4 0 5 ( a) ; 9 1

. 4 0 7 ( a) ( 1 ) ; 9 1 4 0 9 ( a) ( 2 ) ; 9 1

. 4 1 7 ( a) & (b )

.**14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 91.7 (a)**
14 CFR § 91.203 Given the size, weight, speed, and limited operating area associated with the UAS aircraft to be utilized, I am asking exemption from 14 CFR Part 21,Subpart H(Airworthiness Certificates) and §91.203 (a) and (b) (Certifications required), subje ct to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under14 CFR Part 11 and Section 333 of the Reform Act. The Federal Aviation Act U.S.C. 44701 (f) and 333 of the Reform Act both authorize the FAA to Exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the particular UAS. In all cases, an anal ys is of these criteria demonstrated that the UAS operated without an airworthiness certificate, in the restricted environment and under conditions proposed, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an ai rworthiness certificate without the restrictions and conditions proposed. I request an exemption from 14 CFR 91.7 (a) Civil Aircraft Airworthiness. **14 C.F.R. 45.23(b): Marking of the Aircraft** Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally

two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Even though the UAS will have no airworthiness certificate, an exemption may be needed. The word “Experimental” could be placed on the UAS to comply with 45.29 (f) in a size suitable for the available space. The UAS is equipped with LED lights to aid in visibility

. **14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command** Under §61.113 (a) and(b) private pilots are limited to non

- commercial operations, however I can achieve an equivalent level of safe ty as achieved by

current regulations because m y UAS does not carry any pilots or passengers. I have a Private Pilots L icense and will ensure all operations are conducted b y a person with at a minimum a Private Pilots Certificate. **14 CFR 91.9 (b) (2): Civ il Aircraft Flight Manual in the Aircraft**  An exemption to the part will be needed since there is nowhere to place a copy of a flight manual on board the UAS. **14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action**This requires each PIC to take certain action s before flight to insure safety of flight. There is no approved flight manual, however the PI C will take actions prior to flight b y reviewing the weather, flight battery requirements, and ensuring there is a safe location to land and depart so as not to c ause undue hazard to people or property on the ground. The manufactures manual will be used prior to flight to ensure safety. **14 CFR 91.119: Minimum Safe Altitudes** Due to the limitation that operations be conducted at or below 400 feet AGL, an exemption will be necessary to meet 91.119. The ty

pical UAS flight will be operated as follows: 1) Operate the UAS for 10

- 15 minutes per flight, land my UAS according to the manufacturer’s recommended minimum level of battery power. 2) Operate m y UAS only within visual line of sight (VLOS). 3) Alway s obtain all necessary permissions prior to operation. 4) Procedures in place to abort flights in the event of safety breaches or potential danger. **14 CFR 91.121: Altimeter Setting** The UAS is not equipped with an alti meter setting device. GPS will be used on board the UAS to determine altitude by reference to the ground (AGL). **14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions** An exemption from 91.151 will be necessary as the normal flight time will onl y be 10

- 15 minutes. The UAS is fueled by battery power and a long duration flight is not possible. Also since all flights will be conducted Line of Sight (LOS), this requirement is not applicable. **14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b ): Maintenance Inspections**  These regulations require the owner/operator to have the aircraft inspected as prescribed in subpart E of this part. An equivalent level of safety will be maintained because of the small size and limitations of this UAS. Maintenance will be accomplished by the operator pursuant to the owners manual. The operator will ensure that the UAS is in proper working order prior to each flight, perform necessary maintenance, and keep a log of maintenance. The operator is the person most familiar with the UASs operation and is best suited to maintain in an airworth y condition to provide equivalent level of safet y. **3. Commercial and Public Benefits** Granting this exemption will by provide a safe (by way of a unmanned s ys tem) andefficient means to meet technical problems solvable by elevated data collection instruments. Our ty

pical customer base is small to medium size business and individuals who would be unable to acquire this ser vice by manned aircraft due to it being cost prohibited. By

moving these functions to UAS based aircraft not onl y can more people benefit from this service but it will reduce aircraft noise, pollution, reduce airport congestion. In addition, it will reduc e the amount of people and property exposed to the hazards of a manned aircraft fl yi ng at low altitude with the potential for catastrophic results. There are no combustibles on

- board the UAS, thus eliminating the risk of explosion and fire due to a crash. The operation of this UAS will minimize ecological damage and promote economic growth by providing information to companies in the area that would otherwise be unavailable. Additionally, this system would eliminate a distraction to air traffic controllers who must monitor an aircraft that usually wants' to take pictures in the "wrong place at the wrong time" thus reducing workload on ATC. The use of UAS, would allow these services to be provided and thus benefit both the community

and aviation by : 1. Provi ding a lower cost to the individual needing these services. 2. Zero emissions from the UAS. 3. Reduced noise over an aircraft. 4. Reduced hazard to people or property on the ground. The use of a UAV will provide a level of safety at least equal to existin g rules and will only be operated in a safe environment that is strictly controlled. Operations will only be conducted after a careful review of the area and weather conditions. Safety is the number one priority. **4. SUMMARY** Gr anting this exemption is a " win

- win" situation for individuals in need of this service. The community

benefits from reduced pollution and noise. The economy benefits b y the creation jobs for small businesses. The consumer benefits from reducing the cost of this service. The FAA bene fits by regulating the use of UASs so that safet y and accountability can be maintained and monitored.Approval of exemptions allowing commercial operations of UASs in the media

will enhance safety b y reducing risk associated with conventional aircraft o perations. The operation of UASs weighting less than 55lbs b y a certified pilot will enhance safet y to the community

increase awareness of properly flown UASs, eliminate the risk of collision with aircraft operating in the airspace and around airports and provide jobs.
Tommy Turner ThreeD.Space 3278 Deerfield Ct. Williamsburg, VA 23185 (757) 784

- 0979 tommy@threed.space