George A. Mercer

523 S Gay Avenue Callaway, FL 32404 Subject: Exem

ption Request Under Section 333 of the FAA Reform Act Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, I (George A. Mercer) an independent video and photographic service provider , hereby applies for an exemption from the Federal Aviation Regulatio ns (FARs) listed below to allow operation of my Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption(s) would permit myself to pursue commercial interests in providing services to clients using a small advanced sUAV in the following areas: (a) Real Estate (b) Marketing (c ) Special events I affirm that all sUAS flights will occur over private or controlled access property and will do so with the property owners’ consent and knowledge and that only those individuals who have consented or otherwise agreed to be in stated are a where such videography will take place. Regulations from which exemption is requested: (a) 14 C.F.R. Part 21 (b) 14 C.F.R. 45.23 (c) 14 C.F.R. 91.7 (d) 14 C.F.R. 91.9 (e) 14 C.F.R. 91.109 (f) 14 C.F.R. 91.119 (g) 14 C.F.R. 91.121 (h) 14 C.F.R. 91.151(i) 14 C.F.R. 91.203

(j) 14 C.F.R. subpart E 91.401

- 91.417 Unmanned Aircraft System sUAVs are often seen as superior to helicopters or ground based aerial photography systems (i.e. crane, bucket

- truck) due to the smaller device, cheaper equipm ent, lower personnel costs, reduced noise, and much smaller environmental im pact which promotes public safety. I, George A. Mercer, am petitioning for an exemption to operate a DJI Phantom 2 with built

- in HD camera and GPS safety features which limits flight height capability (AGL), limits the distance of flight from its operator, and excludes the sUAS fr om

operation within designated Class B, C, and D airspace including no

fly zones feature. The DJI Phantom 2 also has failsafe function that is triggered in the event communication is lost beween the sUAS and the main controller transmitter. In the event of such transmission loss, the sUAS will return to its point of takeoff and land safely or within a distance to the operator that transmission and control can be regained. These specifications meet with the Model Aircraft Operating Standards as set forth below:
a. The Pilot in Charge (PIC) will only operate the sUAS in line

- of

- sight of a pilot and will operate at sites that are sufficient distance from populated areas within a sterile area described in the FOPM. Such operations will ensure that the sUAS will “n ot create a hazard to users of the national airspace system or the public”. b. When flying the sUAS within five (5) miles of an airport, airport operators will be notified and the operator will give the right of way to avoid flying in the proximity of full

- scale aircraft.
c. Maxim um flight time for each operation will be 30 minutes. d. Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the sUAS.
e. The sUAS will be programmed so that i t will not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from which videography is planned.f. Minim

um crew for each operation will consist of: sUAS pilot (PIC) b

. g. The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, transmitter, stabilization gimbal). h. The sUAS will operate at speeds no more than 50 knots, can hover, and can sim ultaneously move vertically and horizontally. i. Given the small size of the sUAS and the restricted sterile environment with which it will operate, the petitioner’s operations will adhere to the Reform Act’s safety requirements. Public Interest : Granting this request would be in the public interest by offering an effective method of commercially offering real estate property and business advertising at a reduced cost to clients and a reduced intrusion to the general public by avoiding transportation and use of large, unwieldy equipment for the same p urpose. In conclusion, I respectively request exemption under Section 333 to enable myself to operate efficient, limited, low

- risk commercial sUAS operations for the activities stated respecting at all times the space and privacy of the public and its property, while ma intaining airspace safety. Sincerely,
/s/ George A. Mercer 523 S Gay Avenue Callaway, FL 32404 850

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- 4125 mercerg@comcast.net