UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

Petition for Exemption 14 CFR 11.81

IN THE MATTER OF THE PETITION FOR EXEMPTION OF SUPER

- FIE'D LLC. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL
REGU LATIONS SECTIONS PART 21 SUBPART H, 91.103(b), 91.105, 91.109, 91.119, 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING

COMMERCIAL OPERATION OF DJI PHANTOM 2 VISION+ UNMANNED AIRCRAFT SYSTEMS
PURSUANT TO SEC TION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC

LAW 112

- 95)

Submitted on 9/25/2015

Arnie Fie owner Super

- Fie'd LLC

8001 Andrew Franklin Drive

Denver, NC 28037

704 302 3232

ArnieFie@Ya hoo.comIntroduction:

E. Arnold Fie II, the owner of Super

- Fie'd LLC, seeks exemption from the requirements of 14 C.F.R § 91.103(b), 91.105, 91.109, 91.119, 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will allow Super

- Fie'd LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of real estate, special events, film sets and
construction sites within the United States.

Super

- Fie'd LLC was created in 2015 to provide a "for

- hire" entity where the owner's talent, skill, and knowledge of remote control craft can become a blossoming small business for the betterment of the society in which it operates. Arnie Fie owner of Super

- Fie'd LLC is very accomplished in competitive remote control racing in the USA, has consulted, produced, tested,
and developed a myriad of remote control produc ts during his 27 years in the remote control market including testing and proving of individual components that are used commonly in today's UAS such as the motors, speed control units, spread

- spectrum radios, and lithium

polymer batteries. This experience makes the operator a unique and very qualified person for exemption due to his intense knowledge of the components of the craft plus proven skill when it comes to operating a remote craft.

Super

- Fie'd LLC seeks an exemption to operate DJI brand UAV s ystems for compensation or hire within the National Airspace System. Super

- Fie'd LLC desires to operate a DJI Phantom 2, Phantom 2 Vision+, Phantom 3, and Inspire 1. These Unmanned Aerial Vehicles are all four bladed “quad” copter allowing for vertical tak eoff and landing. The units are powered by a Lithium Polymer battery which supplies

power to four of the motors. It is controlled wirelessly through a Ground Control Station allowing it to be operated using a remote and an electronic tablet or smart phone system. All listed UAV comply with all FCC radio frequency regulations and a proof of FCC compliance letter can be provided upon request.Specifications for UAV listed:

- DJI Phatom 2: top speed 29 knots, gross weight approx. 2.20lbs, cubic size of 16"x16"x8".

- DJI Phantom 2 Vision+: top speed 29 knots, gross weight approx. 2.75lbs, cubic size of
16"x16"x8".

- DJI Phantom 3: top speed 31 knots, gross weight approx. 2.82 lbs, cubic size of 18"x18"x8".

- DJI Inspire 1: top speed 43 knots, gross weight approx. 6.50lbs, cubic size of 18"x18"x12".

If this petition is granted, the UAV listed will be operated by Super

- Fie'd LLC will be registered in
accordance with 49 U.S.C. 44103, Registration of Aircraft, and 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.Statements in response to safety concerns and sections of 14 C.F.R. Su per
- Fie'd LLC seeks

exemption:

Petitioner, Super

- Fie'd LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special
Rules for Certain Unmanned Aircra ft Systems, hereby petitions the Administrator to commercially operate an UAS in the National Airspace

System (NAS), and for an exemption from the following requirements:

- 14 C.F.R. Part 21, Subpart H

Based on its size, weight and speed it meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

The Reason Why Granting The Exemption Would Not Adversely Affect Safety:

Safety will not be affec ted without an airworthiness certificate because the process of obtaining an airworthiness certificate is geared toward the certification of manned aircraft and not small UAVs. Small UAVs, like the UAS listed for use are in a separate category of aircraft, as FMRA Section 333 recognizes.

- 14 C.F.R 91.103 (b)

Super

- Fied'd LLC seeks an exemption from the requirements of Section 14 C.F.R. 91.103(b) entitled Preflight Action. If this petition is granted, Super

- Fie'd LLC will be operating an UAS which does not require a runway. The UAS listed for use all take off v ertically without a runway. Therefore it is impossible for the PIC to calculate runway takeoff and landing distances.

The Reason Why Granting The Exemption Would Not Adversely Affect Safety:

Super

- Fie'd LLC believes that safety will be enhanced without the need for a runway Additionally, the size and weight of the UAS is so small, that any takeoff or landing accident would cause minimal damage to persons or property when compared to manned air craft
takeo ff and landing accidents.- 14 C.F.R 91.105

Super

- Fie'd LLC seeks an exemption from the requirement of Section 14 C.F.R. 91.105, entitled flight crew members at stations. Because this is an Unmanned Aerial Vehicle, it is operated
fr om the ground. Therefore, the operator has no need to wear seat belts while flying. Super

Fie'd LLC believes the UAV can be safely operated from the ground and still maintain safety of flight.

The Reason Why Granting The Exemption Would Not Adversely Aff ect Safety:

Super

- Fie'd LLC believes that UAVs are much safer because the PIC is safely on the ground. Any inflight turbulence does not a ffect the safety of the PIC. In the event of a crash, the PIC risks significantly less physical damage from the UAV t han he or she would if inside a manned aircraft during a crash. For this reason, Super

- Fie'd LLC believes that safety is actually improved by operating a UAV instead of a manned aircraft.

- 14 C.F.R 91.109

Super

- Fie'd LLC seeks an exemption from the requirement of Section 14 C.F.R. 91.105, entitled Flight Instruction; Simulated instrument flight and certain flight tests. Super

- Fie'd LLC believes that all forms of flight instruction given on the UAV can safely be given using a dual operator

g round station. Using two remotes, the instructor has the ability to override the student if needed, ensuring the instructor has full control over the UAV at all times while given flight instruction. Without this exemption, it would be impossible for Super

- Fie'd LLC to give any type of UAV flight instruction.

The Reason Why Granting The Exemption Would Not Adversely A ffect Safety:

Super

- Fie'd LLC believes that the same level of safety will be maintained during flight
instruction because the instructor ha s full control of command at all times while giving flight lessons. In the event that the student begins to lose command the instructor can take command exactly as it is done in manned aircraft.- 14 C.F.R. 91.119

Super

- Fie'd LLC seeks an exemptio n from the requirement of Section 14 C.F.R. 91.119 from the minimum safe altitude requirements. This Section prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non

- congested areas. Section 91.119(d)(1) allows for a helicopter to operate at less than those minimum altitudes when it can be operated “without hazard to persons or property on the surface,” provided that “each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA. To provide the intended inspections, the UAS will normally need to be operated within a range of approximately 25 feet from the infrastructure being in spected. Accordingly, due to the nature of the proposed operations, the Operator and the designated observer may at times be less than 500 feet away from structures during the operation, and an exemption is therefore required.

The Reason Why Granting The Exemption Would Not Adversely A ffect Safety:

Super

- Fie'd LLC believes that compared to flight operations with rotorcraft weighting far more than the maximum 55 pounds allowable and the lack of flammable fuel any risk associated with these operations is far less than those presently presented with con ventional aircraft. An equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. As set forth the UAS will be operated in a restricted area where buildings and people will not be expo sed to unnecessary and unplanned operations. Because of the advance notice all affected individuals will be aware of the planned flight operations. Furthermore by operating at such lower altitudes the UAS will not interfere with
other aircraft that are sub ject to the minimum safe altitude regulations.

- 14 C.F.R 91.121

Super

- Fie'd LLC also seeks an exemption from the requirements of Section 14 C.F.R. 91.121, entitled Altimeter Settings, as the listed UAS for use all do not have a barometric alt imeter.
The UAS altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Altitude information is provided to the PIC via the telemetry data link. This information is displayed to the PIC via the ground station tablet interface. This altitude information, combined with visual line of sight will ensure a level of safety equivalent to that of Section 14 C.F. R. 91.121.

The Reason Why Granting The Exemption Would Not Adversely A ffect Safety:

Super

- Fie'd LLC believes that safety will still be maintained because the PIC still has altitude information available to him or her at all times during the flight. This combined with attitude and ground speed information keeps the PIC situation ally aware of the UAS and its surroundings.- 14 C.F.R 91.151(b)

Super

- Fie'd LLC seeks an exemption from the requirements of Section 14 C.F.R. 91.151(b), entitled Fuel requirements for flight in VFR conditions. Super

- Fie'd LLC believes that the standard Lithium Polymer batteries that power the UAS listed will be adequate for the short flights needed for this operation. The listed UAS have enough battery power to fly for a total duration of approximately 13 minutes with an additional 5 minutes of reserve power for additional flying at normal speed. Super

- Fie'd LLC seeks the requested relief because without an exemption from Section 91.151(b), it would not be possible to fly the listed UAS. This would severely constrain the practicality of any a erial video or still photo flight operations that Super

Fie'd LLC proposes to conduct pursuant to this Petition.

Furthermore, safety will be ensured as the UAV listed provide audible and visual warnings to the PIC at the ground station when the UAV exper iences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the UAV will descend and land automatically at the home or sa fe zone.

The Reason Why Granting The Exemption Would Not Adversely A ffect Safety:

Super

- Fie'd LLC believes that safety will still be maintained because the listed UAV would always be flown within line of sight. This ensures that a landing can immediate ly be made within seconds or minutes. Additionally, the ability to takeo ff or land vertically allows the UAV to land on virtually any flat surface. This ensures that the UAV will have plenty of battery reserves allowing it to always be able to safely land after a flight.- 14 C.F.R 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b).

Super

- Fie'd LLC requests relief from these sections as these sections set for the requirements for maintenance that only apply to aircraft with an airw orthiness certificate on the premise the listed UAV do not require airworthiness certificates as set forth in the conditions of
FMRA Section 333.

A maintenance logbook will be developed to record all maintenance, alterations or repairs made on the UAV. Prior to any revenue flight, the PIC will be required to determine
the condition of the UAV in a manner consistent with this exemption.

Super

- Fie'd L LC will use an experienced technician to perform maintenance, alterations, or preventive maintenance on the UAVs using the methods, techniques, and practices prescribed in the UAV operating documents (Monthly Maintenance Log, and UAV Instruction Manual).

F urthermore, Super

- Fie'd LLC will document and maintain all maintenance records for the listed UAV. Super

- Fie'd LLC submits that it will ensure that the listed UAV is in an airworthy condition prior to every flight by determining that the UAVs are in compli ance with the operating documents (Maintenance Log, and UAV Instruction Manual) and that the aircraft is in a condition for safe flight.

Super

- Fie'd LLC will appropriately operate the listed UAV in accordance with the manufacturer’s operatin g manual. The exemption sought will not adversely affect safet y because Super

- Fie'd
LLC will use an e xperienced technician for maintenance and alterations on the UAV using the methods, techniques, and practices prescribed by t he operating documents. Super

- Fie'd LLC believes that safety will not be affected because the procedures established above ensure
the listed UAV will always be maintained and operated in a structured, organized and consistent manner. Using the procedures a bove ensures that each flight is executed with all precautions considered.The reasons why granting Super

- Fie'd LLC’s request would be in the public interest and how it

would benefit the public as a whole.

1) Expanding the availability of affo rdable aerial photos for industry.

Granting this petition will further the public interest by expanding the availability of economically a ffordable aerial cinematography and photography. Historically, the public has used aerial photos for a variety of re asons. These aerial photos and videos have been obtained using manned aircraft, costing hundreds and thousands of dollars per hour to operate. Granting this petition will increase the quality of aerial photography services, while at the same time
decreasin g the price.

This service will allow for the following:

- Enhanced and dynamic real estate marketing, benefiting property owners and real estate
agents

- Crop surveying for the agricultural industry (field drainage monitoring, crop insurance documentation, pesticide monitoring, etc), which will lead to increased farming e fficiency benefiting both farmers, consumers, and environment.

- Insurance claim documentation for insurance companies such as hail damage, crop damage, bridge collapses, flooding, etc. whic h will benefit the insurance companies and consumers of insurance products.

- Construction progress for residential, commercial, and industrial construction companies.

- Wetland and water drainage mitigation for public works departments, which will enhance t he ability of civil engineers to plan for water drainage mitigation

- Power line and pipeline utility inspection services for utility companies.

- Liberty for potential applications to freely develop.

The increased efficiency and lower cost of operating a UAV for aerial applications will benefit the economy as a whole by allowing scarce resources, such as aircraft fuel and talent of personnel to be used in other areas of the business or economy in whole. This will ensure that the United States remains compe titive on the global market for aerial applications and ensure that more jobs stay located within the United States.2) Increased Public Safety

The listed UAV all weighing less than 7 pounds pose a very small threat to people and property on the ground in the event of an uncontrolled landing. The damage a roughly 7 lb UAV can do is very small compared to the damage that a 4000 lb aircraft with hundreds of gallons of fuel onboard and human life. In other words use of the UAV has less physical potential f or collateral damage to life and property compared to a manned aircraft.

3) Reduced Levels of Air and Noise Pollution

Using the listed UAV to conduct aerial operations instead of manned aircraft will greatly benefit the public by reducing the levels of air and noise pollution. Small UAVs are much more energy

e fficient than traditional manned aircraft. By using battery pow er with electric motors the listed UAV produce no air pollution and are much more environmentally friendly than the traditional internal combustion aircraft engines that are typically utilized for aerial video and photography. These manned aircraft burn ap proximately 10

- 25 gallons per hour of aviation fuel. The listed UAV also eliminate a lot of noise pollution as the small propeller blades and electric motors produce only a fraction of the noise level that traditional fixed

- wing aircraft or helicopters

pro duce.

4) Reduced Congestion of the National Airspace System

Granting this request also benefits the public as a whole by reducing the quanity of manned aircraft and relieving of congestion of the NAS. By reducing the number of manned aircraft operating in the NAS this will relieve the air traffic control system of air traffic control
communication volume and tasks of air traffic controller to monitor the manned aircraft in their area. Also because the listed UAV do not need a runway or airport to operat e this would result
in fewer aircraft being handled by air traffic control during all phases of flight operations. This will allow the air traffic control system to focus their resources more on the needs of other types of manned flights.Planned Intent of Operation of UAV by Super

- fie ’ d LLC.

1: The UAV may not be operated at a speed exceeding 50 knots.

2: The UAV must be operated at an altitude of no more than 4 00 AGL

.

3: The UAV 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 vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.

4: All operations must utilize a safety observer (SO). The SO may be used to satisfy the V LOS

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must

be able to communicate verbally at all times. Electronic messaging or texting is not

permitted during flight operations. The PIC must be designated before the fligh t and

cannot transfer his or her designation for the duration of the flight. The PIC must ensure

that the SO can perform the functions prescribed in the operating documents.

5: The SO must not perform any other duties beyond assisting the PIC with seeing and

avoiding other air traffic and other ground based obstacles/obstructions and is not

permitted to operate the camera or other instruments.

6: The operating documents and the grant of exemption must be accessible during UAV

operations and made availa ble to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating documents, the conditions and limitations contained

in the grant of ex emption take precedence and must be followed.7: Prior to each flight the PIC must inspect the UAV to ensure that it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe operation of the UAV, the

aircraft is proh ibited from operating until the necessary maintenance has been performed

and the UAV is found to be in a condition for safe flight. The Ground Control Station must

be included in the preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

8: Any UAV that has undergone maintenance or alterations that affect the UAV operation or

flight characteristics, e.g. replacement of a flight critical component, must undergo a

functional test flight. The PIC who con ducts the funct ional test flight must make an entry

in the aircraft records.

9: The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant sections of the

operating documents.

10: The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the

aircraft records, including total time in service, description of work accomplished, and the

signature of the authorized person returning the UAV to service.

11: Each UAV operated under this exemption must comply with all manufacturer Safety

Bulletins.1 2 : The UAV may not operate within 5 nautical miles of an airport refer ence point as denoted

on a current FAA

- published aeronautical chart, or within the lateral limits of class B, C or

D airspace as denoted on a current FAA

- published aeronautical chart.

1 3 : If the UAV loses communications or loses its GPS signal, it must r eturn to a pre

determined location within the planned operating area and land or be recovered in

accordance with the operating documents.

1 4 : The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the oper ating documents.

1 5 : The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough power to fly at normal cruising speed to the intended

landing point and land the UA with 25% battery power remaini ng.

1 6 : All aircraft operated in accordance with the exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings mu st be as

large as practicable.

1 7 : The UAV must remain clear and yield the right of way to all manned aviation operations

and activities at all times.

1 8 : The UAV may not be operated by the PIC from any moving device or vehicle.19 : Flight operations must be conducted at least 500 feet from all nonparticipating persons

(persons other than the PIC, SO, operator trainees or essential persons), vessels,

vehicles, and structures unless: a. Barriers or structures are present that suff iciently

protect nonparticipating persons from the UAV and/or debris in the event of an accident.

The operator must ensure that nonparticipating persons remain under such protection. If

a situation arises where nonparticipating persons leave such protec tion and are within

500 feet of the UAV, flight operations must cease immediately and/or; b. The aircraft is

operated near vessels, vehicles or structures where the owner/controller of such vessels,

vehicles or structures has granted permission and the PIC has made a safety assessment

of the risk of operating closer to those objects and determined that it does not present an

undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential

persons do not present an undue hazard to those persons per § 91.119(a).

2 0 : All operations shall be conducted over private or controlled

- access property with

permission from the land owner/controller or authorized representative. Permission from

land owner/controller or authorized representati ve will be obtained for each flight to be

conducted.

Super

- Fie ’ d LLC will not allow any PIC to operate the UAV listed unl ess that PIC has

demonstrated that they are able to sa fely operate the listed UAV in a manner consistent with

this exemption, i ncluding evasive and emergency maneuvers and maintaining appropriate

distances from people, v essels, vehicles and structures.Conclusion of Request of Exemption

My belief is simply that small UAV when used by experienced and responsible operators will
of fer the society at large a safe r , ecology friendly, cost effective and efficient means to perspectives of t he world for indus trial or recreational purposes. I hereby request that the exemption is grante d to Super

- fie ’ d LLC without delay.

Best regards,

Arnie Fie owner Super

- Fie'd LLC

8001 Andrew Franklin Drive

Denver, NC 28037

704 302 3232

ArnieFie@Ya hoo.com