Tom Chapman 6626 Cedar Brush San Antonio, TX 78257 (210) 861-7614 tomrv4@me.com

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590 January 27, 2016

Subjeet:"Exemption Requestto Sectien-333 ofthe FAA Reform Act and Part 11**~-~'"''M-~** 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 SirorMadam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, I, Tom Chapman, a licensed Private Pilot, hereby applies for an exemption from the Code ofFederal Regulations (C.F.R), Federal Aviation Regulations (FARs) identified,to allow commercial operation oflightweight Unmanned Aircraft Systems (UAS) for

..aerial imaging avdvideo. This exemption is made based on information outlined in this petition, to allow commercial operation ofa DJI Phantom 3 Advanced, and DJI Phat;ttom 3 Professional multi-rotor equipped with a three-axis**gimbal~d** camera, so long as operations are conducted within and under the conditions outlined herein,or as maybe established bythe Federal Aviation Administration (FAA) as required by 333.
1. TYPES OF OPERATION:
Therequested exemption would permit the operation ofsmall, unmanned .niuHTrofor

# aircra:ffuri.der controlled coridifioiis'io-provide the following services to the community;

a. Real Estate photography b. Aerial Survey c.**Aeri~l** Photo/video d. Promotional advertising material e. Inspections ofreal**'es~ate** properties f. Public entity support operations 

### g. Precision agriculture aerial surveying ;h.· Communications infrastructure inspection/monitoring 

### i. Wildlife and forestry monitoring 

### j. Pipeline inspection and patrollingk. Construction site inspection and monitoring 

### 1. News media coverage This exemption would permit operation ofan ultra-light weight, unmanned (piloted by remote control) inpredetermined 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 ofan Observer. Operations would be conducted after carefullyreviewing, inspecting, and examining the area ofaerial operation to ensure the safety ofpersons and property.


### 2. REQUESTED RELIEF:
I am requesting a grant ofexemption ofthe following sections ofTitle 14 ofthe Code of Federal Regulations:
0 14 CFR21; 0 14 CFR 91, et seq; 0 14CFR 45.23 (b); 0 14 CPR 61.113 (a) & (b); 0 14 CPR 407 (a)(1); 0 14 CPR 409 (a)(2); 0 14 CPR417 (a) & (b).
I am also requesting an Exemption from Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations for the following:
0 14 CFR45.23 (b); 0 14 CPR Part 21; 0 14 CPR 61.113 (a) 

### & (b); 0 91.7 (a); D 91.9 (b) (2); 0 91.103 (b); 091.119; 

## cr9T.r2T; 0 91.151 (a); 0 91.203 (a) & (b); 0 91.405 (a); 0 91.407 (a) (1); 0 91409 (a) (2); 0 91.417 (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 CPR Part 21,Subpart H(Airworthiness Certificates) and §91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level ofsafety under14 CPR Part 11 and Section 333 of the Reform Act.
The Federal Aviation Act U.S.C. 44701 

### (f) and 333 ofthe Reform Actboth authorize the FAA to Exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteriademonstrated that the UAS·operated·'withoutanairworthiness eert-ifieate; in the restricted environment and under conditions proposed, will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. I request an exemption from 14 CPR 91.7 (a) Civil Aircraft Airworthiness.


### 14 C.F.R. 45.23(b): Marking ofthe Aircraft
Furthermore I request an exemption from §45.23 Marking ofthe aircraft because myUAS will not have a cabin, cockpit orpilot 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 maybe needed. The word "Experimental" could beplaced 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)atiC1{6)

# prfvate pilots··ru-e·limited to :non-commercial operations, however I can achieve an equivalent level ofsafety as achieved by currentregulations because myUAS does not carry any pilots orpassengers. I have a Private Pilots License and will ensure all operations are conducted by a person with at a minimum a Private Pilots Certificate.


### 14 CFR 91.9 (b) (2): Civil 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 onboard the UAS.


### 14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

# ________________

# .... ___

This requires each PIC to take certain actions before flight to insure safety of flight. There is no approved flight manual, however the PIC will take actions prior to flight byreviewing the weather, flight batteryrequirements, and ensuringthere is a safe location to land and depart so as not to cause undue hazard to people orproperty onthe ground. The manufactures manual will beused prior to flight to ensure safety.


### 14 CFR 91.119: Minimum Safe Altitudes
Due to the limitation that operations be conducted at orbelow 400 feet AGL, an exemption will be necessary to meet 91.119. The typical UAS flight willbe operated as follows: / 1) Operate the UAS for 10-15 minutes per flight, land myUAS according to the

manufacturer's recommended mtnimunrtevel ofbatterypower. 2) Operate myUAS only within visual line ofsight (VLOS). 3) Always obtain all necessarypermissions prior to operation. 4) Procedures in place to abort flights in the event ofsafetybreaches orpotential danger.


### 14 CFR 91.121: Altimeter Setting
The UAS is not equipped with an altimeter setting device. GPS will be used on board the UAS to determine altitude byreference 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 only be 10- 15 minutes. The UAS is fueled bybatterypower and a long duration flight is not possible. Also since all flights will be conducted Line ofSight (LOS), this requirement is not applicable.


### 14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & 

### (b): Maintenance Inspections Thest:rregulations requirtftnirowfiet/operatOr to havethe aircraft inspected as prescribed in subpart E ofthis part. An equivalent level ofsafety will be maintained because ofthe small size and limitations ofthis UAS. Maintenance will be accomplished bythe operator pursuant to the owners manual. The operator will ensure that the UAS is inproper working orderprior to each flight, perform necessary maintenance, and keep a log ofmaintenance. The operator is theperson most familiar with the UASs operation and isbest suited to maintain in an airworthy condition to provide equivalent level of safety.


### 3. COMMERCIAL AND PUBLIC BENEFITS: Granting this exemption will provide a safe (byway ofa unmanned system) and efficient means to meettechnical problems solvableby elevated data collection

# ________________

# .... ___

instruments. Our typical customerbase is small to medium sizebusiness and individuals who would beunable to acquire this service bymanned·aircraft due to it being cost prohibited. Bymoving these functions to UAS based aircraft not only can more people benefit from this service but it will reduce aircraft noise, pollution, reduce airport congestion.
In addition, it will reduce the amount ofpeople and property exposed to the hazards ofa manned aircraft flying 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 ofthis UAS will minimize ecological damage and promote economic growth byproviding information to companies in the area that would otherwisebeunavailable. Additionally, this system would eliminate a distraction to air traffic controllers who must monitor an aircraft that usually wants' to take pictures inthe "wrongplace at the wrong time'"thus reducing workload on**Are~** The use ofUAS, would allow these services to beprovided and thus benefit both the community and aviation by: 1. Providing 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 orproperty onthe ground.
The use ofa UA V will provide a level ofsafety at least equal to existing rules and will onlybe operated in a safe environment that is strictly controlled. Operations will onlybe conducted after a careful review ofthe area and weather conditions. Safetyis the number one priority.
4. ADDITIONALLY: 1) I will not operate within 5 miles ofan airport unless prior contact to Air Traffic Control orthe airport managerhas been made. 2) I will land myUAS prior to manufacturer recommended minimum level ofbattery power. 3) My UAS uses GPS and a flighrsafetyTeaturewhereby itreturns to a preprogrammed position and then slowlylands ifcommunication with the remote control pilot is lost. 4) I actively analyze flight data and other sources ofinformation to constantly update and enhance safetyprotocols. 5) I conduct extensive pre-flight inspections and protocol, during which safety carries primary importance. 6) I always obtain all necessary permissions prior to operation. 7) I have procedures inplace to abort flights in the event ofsafetybreaches orpotential danger. 8) I will pilot myUAS through remote control byline ofsight, with the assistance ofan observer.

### 5.SUMMARY Granting this exemption is a "win- win" situation for individuals in need ofthis service. The communitybenefits from reduced pollution and noise. The economy benefits bythe creationjobs for small businesses. The consumer benefits from reducing the cost ofthis service. The FAA benefits byregulating the use ofUAS's so that safety and accountability can be maintained and monitored. Approval ofexemptions allowing commercial operations ofUAS's in the media will enhance safetybyreducing risk associated with conventional aircraft operations. The operation ofUAS's weighting less than 55lbs by a certified pilot will enhance safety to the communityincrease awareness ofproperly flown UASs, eliminate the risk of collisionwith aircraft operating in the'airspa'ce andaround airports andprovide

## Jobs. , Thank you, 

# Qot\A 

# CRcfTomChapman 6626 Cedar Brush San Antonio, TX 78257 (210) 861-7614 tomrv4@me.com