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January 15, 2016 

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U. S. Department ofTransportationDocketManagement**Syste~J:70q** 

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### Re: Exemption·Request Section 333 oftheFAA Reform Act and Part 11 ofthe FederatAviationRegulations ·
Dear Sir orMadam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of1 2012'(the·\'Reform Act"), JosephP Louchheim, a professional photographer (the "Applicant"), planned operator ofSmall Unmanned Aircraft Systems ("sUAS") seeks an exemption fron{Fedetal''Aviation Regulations ("PARs") listed below and discussed in AppendixA. 'Attached, as AppendixC, is a summaryofthis request'.·

.**~~** · !, /:; ; The requested exernptidi\'·Wouid allo\VtheApplicimt**to~**safely,**efficientlY/~h1d** · · economically use commercial sUAS in the National Airspace System (NAS), so long as such'operatibns>are'ebnducted within

## and tinder theconditions**butlined'het~in**

## or as·may be established bythe'FAA as required by Section 333. As described more fully below, the requested exemption would authorize the Applicant to perform commercial operations with sUAS that will provide the following benefits:

1. Commercial use ofsUAS to perform aerial photography brings a new and more informedperspective to the end user. 2. The use ofsUAS will decrease congestion in the NAS along withreducing the noise and air pollution generated during traditional manned aircraft flight operations. 3. Operation ofsUAS will substantially reduce the risk to life and property inthe air, and
onthe ground, which is commonly associated withtraditional manned aircraft flight operations. 

### 4: Sirn1lar'tcithe current manned aircraft flight operations that have beenconducted for manydecades, sUA.S 0used·for simrlit:'rtask's will not·generateany

### ileW"pFivacy iSsues;· '·

... ) ( ', Apptovai ofthis exe'mption would therebyenharic'e 'safety:iilid fulfillthe;Sectetary of Transportation's (the FAAAdministrator's) responsibilities under Section 333(c) ofthe Reform Actto "establishrequirements for the· safe operation 'ofsuch aircraft systems in the national airspace sys,tem.''

. ' , ·'· '· · The\name

## and· addtess ofthdtpplicantare: Joseph P.Louchheim

.
·509' SaggMain Street;'PO Box 8 'Sagaponack, 

### NY 11962 , ·· · Phone:631-553-6775 Email:jplll962@gmaiLcomThe regulations from which the exemption isrequestedare as follows: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) &(b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) &(c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) &(9); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(l); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) Appendix A discusses each rule listed above and explains why exemptions pursuantto the proposal set forth in this letter are appropriate, provide an equivalent level ofsafety, and are in the public interest. QUALIFICATION FORAPPROVAL UNDER SECTION 333 OF THE REFORM ACT

The proposed operations inthis petition for exemption qualify for expedited approval under Section 333 ofthe Reform Act. Each ofthe statutory criteria and otherpotentially relevant factors are satisfied.

The proposed operations would permitthe use ofsmall and relatively inexpensive UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access, and; (4) wouldprovide an increased level ofsafety beyondthat existing when fixed orrotor wing aircraft are used to accomplish the same purpose.
The sUAS's planned to be operated are DJI Phantom 3 Professional, and a DJI Inspire weighing 7 Ibs. or fewer including payload. It would operate, under normal conditions, at a speed ofno more than 30 knots. The principal constructionmaterial ofthe sUAS is plastic. Operations will be performed byJoseph P Louchheim "Pilot in Command" (PIC),
as outlined below, to insure that the sUAS will "not create a hazard to users ofthe national airspace system orthe public." Given the small sizeofthe sUAS involved and the pre-planned environment within which they will operate, the applicant believes that these operations fall squarely within that zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofsUAS to commence immediately. Also, due to the size ofthe sUAS and the pre-defined, restricted area in which the sUAS will operate, approval ofthe application presents no national security issue. The operation ofsUAS by knowledgeable

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professionals will serve to enhance safety, add to thepublic benefit, and reduce environmental impacts related to current methods ofmanned aircraft flight operations. These limitations and conditions to whichthe PIC agrees to be boundwhen conducting commercial operations under an FAA issued exemption:

1. Safety will bethe first and foremost consideration in any sUAS operation. 2. The sUAS pilot will be considered Pilot in Command (PIC), whether flying or supervising, and will be responsible for safe operation ofthe flight. ·
3. Flights will be operated within line ofsight ofthe PIC and/or an observer.

4. The sUAS will weigh less than 4 Ibs. total.

5. Flights will be operated in Class G airspace

. 6. Flights will be operated under visibility and cloud clearance requirements equivalentto Visual Flight Rules (VFR).

7. The sUAS will at all times give way to any aircraft carryingpersons.
8. Joseph P Louchheim and a secondary person will be at a all flights

9. Prior to a sUAS flight, an area ofoperation will be established. This area ofoperation will include a defined lateral anc.rvertiCal area, where the sUAS will operate. Safety procedures will be established for persons, property and applicable airspace within the
area ofoperation.

lO.The sUAS shall operate from on -site takoff/landing locations directly nextto the PIC and/or Observer.

11. Flightplanning will include flight completion with at least 20% battery power remaining as measured by the sUAS or appropriate timing.

12.The sUAS will be equipped with an autopilot system. Forexample, the sUAS will utilize GPS navigation for stability andreliability. failsafe's, return-to-home (RTH), PIC will have control ofthe flight at all times. features, among otherbuilt-in safety features.

13.A Ground Stationwill be connected, byradio communication, to the sUAS during the entire flight, which will give the PIC flight information such as GPS Position, Altitude, Battery Remaining, and othertelemetry information.

14.A briefing will be conducted inregard to the planned sUAS operations priorto operation at each newlocation. Allpersonnel who will be performing duties within the boundaries ofthe area ofoperation will be present for this briefing.15.All required permissions and permits will be obtainedfrom appropriate state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

16. Written, electronic, and/or oral permission from the relevant property owners will be obtained priorto an operation.

17. The sUAS pilot will be trained in advance for the safe operation ofthe sUAS to be operated. This will include operation ofthe sUAS both in normal and emergency modes ofoperation, and will include familiarization withthe operation manual (or similar) if published by the sUAS manufacturer. Training will also include types ofmaneuvers to be performed and the safe operation in relation to persons, property and applicable airspace.


### Itis the applicant's beliefthatthe size, weight, speed, operating environment, and operating capabilities provide an "equivalentlevel ofsafety" orbetter when operating a sUAS for the public interest as outlined in Section 333 ofthe Reform Act. Itis requested that the FAA issue an exemptionto permit safe, legal, commercial sUAS operationbythe applicant as soon as possible.



## •AppendixA EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

The applicantrequests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofsUAS's:

14 CFRPart 

### 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)

Section 91.203(a)(l) requires all civil aircraft to have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR 

### § 91.203(a)(l). Giventhe size ofthe aircraft (less than 15 Ibs.) and the limited operating
area associated with its utilization, it is unnecessary to go through the certificate of ainaorthiness process under Part 21 Subpart H to achieve or exceed current safety levels.

Such an exemptionmeets the requirements ofan equivalentlevel ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe sUAS involved.

In this case, an analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The sUAS weighs less than 15 Ibs. fully loaded. Itwill not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area predisclosed and in compliance with conditions set forth herein. Operations under this exemption will betightly controlled and monitored by boththe operator, pursuant to the conditions set forth above, and by local public safetyrequirements. The FAA will have advance notice ofall operations through the filing ofNOTAMs. Receipt ofthe prior permission ofthe land owner, the size ofthe aircraft, the lack offlammable fuel, and the fact that the aircraft is carriedto the location and not flown there all establishthe equivalent level ofsafety. The sUAS provides at least an equivalent, and most likely exceeds, level ofsafety to that ofsuch operations being conducted with conventional aircraft that would be orders-of-magnitude larger and would be carryingpassengers, cargo, and flammable fuel.

14 CFR. § 45.23 & 91.9(c): Marking ofthe Aircraft Regulation 45.23 provides: (a) Each operator ofan aircraft must display onthat aircraft marks consisting ofthe Roman capital letter "N" (denoting United States registration) followed bythe registration number ofthe aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter.(b)When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, orpilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," 'light-sport," "experimental," or "provisional," as applicable. Regulation 91.9(c) provides: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with part45 ofthis chapter.

The sUAS has no entrance to the cabin, cockpit, orpilot station onwhichthe markings
can be placed. Giventhe size ofthe sUAS, two-inch lettering will be impossible. Official marking systems for sUAS have not yet been established for operations inside the NAS. The applicant is prepared to mark the sUAS with the name ofthe organization and location or origin and fulfill any otherrequest by the FAAto this topic in accordance to § 45.29(f) where the pilot, observer, and others working withthe sUAS will see the identification ofthe sUAS.

The FAA has issued the following exemptions to this regulation; see ExemptionNos. 8738, 10167, 10167Aand 10700.**-~-----~--,4** CFR§61.113(a)**&(b);liT.T3'3ti]:Pr1vatt-YH'OrPi1Vil~ges** and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations.
Section 61.113(a) &(b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the sUAS inthis case is remotely controlled with no passengers orproperty ofothers onboard. Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command ofan aircraft for compensation orhire. The applicant respectfhlly proposes that operator requirements should take into account the characteristics ofthe particular sUAS. Most sUAS autopilot's have a high degree ofpre-programmed control and various built-in technicai capabilities that strictly limitthe potential for operation outside ofthe operating conditions set forth in the exemption application. Hands-on experience with the sUAS are a far more effective guarantee offlight safety than a commercial pilot certificate would be, until the FAA Pilot Certificate requirements catch up to the sUAS technology.

The sUAS autopilots have an all-digital softwareplatform with advanced features previously restricted to full size unmanned aircraft. Automated features and advanced flysafe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility.

• The system can autonomously fly a programmed flight path orfly in manual mode

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• Flight time and battery minutes are displayed;at all times. The system will return home and land automatically ifuser-configurable limits are reached. Flight safety is a priority, no matter the operating environment orproject. sUAS offer superior safety overmanned aircraftby removing the need for people to be onboard in potentially dangerous situations. Withmultiple builtin safety features, sUAS platforms exceed manned operations withrespect to safety.

• The sUAS automatically detects potential issues- with configurable automated response behavior such as a return-home-and-land routine

• The sUAS self-calibrate all oftheir sensors and perform required failsafe preflight tests prior to takeoffto checkfor errors

• The sUAS have the ability to set up visual no-flyzones or create a virtual fence so the sUAS can't fly horizontally or vertically beyond the preplanned flight area

• The sUAS have battery minutes and flight time displayed at all times. The system will return home and land automatically ifuser-configurable limits are reached

• The sUAS auto detecta lost GPS, warns the pilot and initiates an immediate landing.

• Lowbattery on the sUAS triggers a Non-Fatal Warning alarm to return home, land and replace the battery

• IfsUAS detect a lost-link to the Ground Stationthe vehicle will perform its pre-definedNon-Fatal ConditionResponse.
Giventhese safety features, the applicantproposes that operators ofsUAS withthese features should not be required to hold a commercial orprivate pilot certification. Instead, operators should be required to:

• have completed a training program for operation ofthe sUAS, ifavailable.

• have completed

# IS hours (or 150 flights) oftraining on the sUAS and/or simulator before commencing commercial operations. The applicant notes t.!:lat the FAAhas found that safety factors permitted operation ofsUASs by operators with these qualifications in the case ofoperations pursuant to public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilotrequirements for commercial operations.Given these conditions and restrictions, an equivalent level ofsafety will be provided by allowing operation ofthe sUAS without a private pilot's certificate or a commercial pilot's certificate, underthe conditions set forthherein.

The risks associated withthe operation ofthe sUAS (given its size, speed, operational capabilities, and lack ofcombustible fuel) are so diminished from the level ofrisk associated with private pilot operations or commercial operations contemplated byPart 61 with conventional aircraft (fixed wing orrotorcraft), that allowing operations ofthe sUAS as setforth above meets or exceeds the present level ofsafetyprovided under 14 C.F.R. 

### § 61.113(a) &(b) and does not rise to the level ofrequiring a commercial pilotto operate the aircraft under§ 61.133(a).

14 CFR § 91.7(a): Civil aircraft airworthiness. This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of sUAS without an airworthiness certificate, no standard will exist for airworthiness ofthe sUAS. Given the size ofthe sUAS and the previous COAs issued for similar sUAS, an equivalent level ofsafety will be achieved by ensuring compliance withthe given sUAS manuals and use ofsafety checklists priorto each flight.

14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. The regulation provides: No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manuai is not required by §21.5 ofthis chapter, unless there is available inthe aircraft a current approved airplane orRotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Given the size ofsUAS, they have no ability orplace to carry such a flight manual onthe aircraft, not only because there is no pilot onboard, butbecause there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be achieved by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAAhas issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 CFR § 91.103: Preflight action This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraft an exemption will be needed. An equivalent level ofsafety will be provided by following a comprehensive preflight checklist. The PIC 

### will take all actions including reviewing weather, flight battery requirements, landing andtakeoff distances and aircraftperformance databefore initiation offlight.

14 CFR § 91.109(a) & 91.319(a)(1): Flight Instruction These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.The sUAS are remotely piloted aircraft and bydesign, do nothave fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates withthe aircraft viaradio communications. The flight planis either manually controlled through point- and-click navigation orpreprogrammed as way points into the auto pilotbefore or during flight and only inunusual circumstances will the pilot input control functions to alter the pre-programmed flight. Given the size and speed of the sUAS, an equivalent level ofsafe training can still be performed without dual controls because no pilot orpassengers are aboardthe sUAS, and all persons will be a safe distance away should the sUAS experience any difficulties during flight instruction. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction inexperimental aircraft. See Exemption Nos. 5778K 

### & 9862A.

14 CFR § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of500 feet above the surface, except over open water or sparselypopulated areas. Inthose cases, the aircraft may not be operated closerthan 500 feet to anyperson, vessel, vehicle, or structure.

Because aerial survey, photography, mapping and inspection work mustbe accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level ofsafety will be achieved giventhe size, weight, speed, and material with which sUAS are built. Also, no flight will be taken without the permission ofthe land owner or those who control the land. Because ofthe advance notice to the landowner, all affected individuals will be aware ofthe flights. Comparedto aerial survey operations conducted with aircraft orrotorcraft weighing far more than 151bs. and carrying flammable fuel, any risk associated with these operations will befar less than those currently allowed with conventional aircraft operating at orbelow 500 feet AGL. Indeed, the low-altitude operations ofthe sUAS will maintain separation between these sUAS operations and the operations ofconventional aircraftthat must comply with Section 91.119.

14 CFR § 91.121: Altimeter Settings Section 91.121 requires a person operating an aircraftto maintaincruising altitude or flight level byreference to analtimeter that is setto the elevation ofthe departure airport
orbarometric pressure. Some sUAS have a barometric pressure sensor, while others only
use GPS for elevation or altitude. When a barometric pressure sensor is onthe sUAS, it is typically "zeroed" atthe point oftake-off; this is right next to the PIC and not at a departure airport. The altitude reading will be relative to that point and not a known elevation. The equivalent level ofsafety will be achieved by the PIC confirming the elevation or altitude ofthe launch site. Thealtitude ofthe sUAS will also be displayed

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viatelemetry on the Ground Station and will be constantly monitored by the PIC during the entire flight operation.

14 CFR § 91.15l(a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed-(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The different sUAS batteries provide a variety ofpowered flight times. An exemption from§ 14 CFR 91.151 is therefore required.

The applicant believes that anexemption from 14 CFR § 91.151(a) is safe and within the scope ofa prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporationto operate without compliance with 91.15l(a)). Operating the sUAS, without 30 minutes ofreserve fuel does not engenderthe type ofrisks that Section 91.151(a) was meant to prevent giventhe size and speed at which the sUAS operates. The fact thatit carries no pilot, passenger, or cargo also enhances its safety. In the unlikely eventthat the sUAS should run out offuel, it would simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation.

The applicant believes that an equivalent level ofsafety canbe achieved by maintaining 20% ofreserve fuel (or battery), which would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area.
The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808.

14 CFR § 91.203 (a) &(b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows: (a)

... no person may operate a civil aircraft unless it has

... an appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that itis legible to passengers or crew.
The sUAS fully loaded weigh less than 15 Ibs. As such, there is no ability or place to carry certification and registration documents or to display them onthe sUAS. In addition, there is no pilot onboard the aircraft. An equivalent level ofsafety will be achieved bykeeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them. The FAAhas issued numerous exemptions to this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR § 91.405(a); 407(a)(l); 409(a)(2); 417(a): Maintenance Inspections Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections,except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

..." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance ofan air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records ofapproval ofthe aircraft for return to service.

The sUAS are nearly maintenance free, they perform automatic pre-flight checks and the failure ofany check will preventtake-off. Checks which cannot be done bythe system will be performed by a qualifiedpersonpriorto each flight and at predefined intervals as part ofa maintenance schedule. Pre-flight checklist includes: l.Visual inspection ofthe airframe 2.Visual inspections ofrotor integrity 3.Check charge ofall batteries (aerial vehicle, command station, radio repeater station)

An equivalent level ofsafety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. The operator ofaUAS will ensure that it is inworking order prior to initiating flight, perform required maintenance, and keep a log ofany maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to
ensure an equivalent level ofsafety. Ifinechanical issues arise, the UAS can land immediately due to the predetermined area ofoperation. Moreover, the UAS's small size, carrying capacity, and the fact that flight operations will onlytake place in restricted
areas for limitedperiods oftime, create less risk than the same factors associated with conventional fixed-wing aircraft and rotorcraft performing the same operation.
APPENDIXC SUMMARY OF SECTION 333 EXEMPTION REQUEST Joseph P Louchheim, a professional aerial photographer, hereby provides pursuantto Part 11 a summary ofhis exemption application to allow commercial operation ofsUAS for aerial photography in support ofgovernment entities, agriculture industry, utility companies, local infrastructure, scientific studies, wildlife monitoring, mining, surveying, forestry, and much more. AU ofwhich are critical to the well-being ofthe general public. An exemption is requested from the following regulations: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) &(b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) &(c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) &(b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a).