My name is Salvatore C Gibilisco and I am the founder of Air 2 Ground Imaging

located in Delran, New Jersey. W e are a small design, photography and video production business that began in 2014. I am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that Salvatore C Gibilisco of Air 2 Ground Imaging owner of a unmanned aircraft system (UAS) be granted exemption from the Federal Aviation Regulations (FARS) listed within so that I may operate my UAS commercially in airspace regulated by the Federal Aviation Administration. This exemption would allow operation of my UAS for the purpose of aerial photography, aerial videography to augment real estate listing video and or real estate prope rty developers and or golf course design.

Air 2 Ground is equipped with a DJI Phantom 3 Professional (4) blade quad copter weighing 6 lbs. 7.5 ounces. The UAS has a maximum airspeed of 30 knots. Using remote controller operating on frequency 5.728

- 5.850GH Z /2.400

- 2.483GHZ. The Phantom 3 Professional is equipped with built in ground support technology that allows it to fly utilizing GPS for stability, tracking, safe flight mode and return to home feature in the event of loss of remote control signal or cri tical low battery. All flights start with a pre

-flight safety check and all flight data are recorded. The Phantom 3 Professional is equipped with a fixed position camera that sends a live video signal to the controller allowing the (PIC) person in control to monitor real time video.

Flight data, speed height, distance, battery level and general aircraft conditions are also displayed during operation. Phantom 3 Professional battery has a flight time of 12 minutes and is therefore always returned to original take off point and always flown utilizing VLOS. I have invested a considerable amount of money and have logged over 10 hours with this particular UAS and trained 15 hours with other UAS operators equipment and find that this model to be far superior in fl ight, safety and reliability. My request for exemption would allow me to offer services to my clients at a considerable discount compared to using Helicopters and fixed wing planes that pose severe safety risk to accomplish the type of aerial coverage need ed in the real estate market.

UAS Safety Operating Parameters Wewill abide by the following additional operating conditions under this exemption, which ensures a level of safety during UAS flight.

Operate UAS below 400 feet and within a radius of 1000 feet from PIC always maintaining VLOS. Obtain permission from the owner/controller of any vessels, vehicles and Structures when operations may be conducted closer than 500 feet to any such vessels, vehicles or structures; we will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard.Operate the UAS for 8

- 12 minutes per flight.

Land UAS prior to the manufacturer's recommended minimum level of battery
power. Operate UAS during dayl ight hours only within visual line of sight (VLOS) Utilize the UAS' global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost or battery becomes critically low Conta ct respective airports if operations will be within 5 miles to advise them of h estimated flight time, flight duration, elevation of flight and other pertinent information. Always obtain all necessary permissions prior to operation Have procedures in place to abort flights in the event of safety breaches or potential danger. Review weather reports prior to flight and never operate UAS in unsafe conditions, high wind, low clouds or conditions that hinder visibility. Only operate in safe environments that are strictly controlled, are away from power lines, elevated lights, airports and densely populated areas (defined by areas depicted in "yellow" on VFR charts and through obtaining information regarding congested areas from the local Flight Standards District Office (FSDO); Also conduct extensive preflight inspections and protocols, during which safety carries primary importance The PIC will also have a minimum of 5 hours logged on this craft and 10 hours minimum flying UAS quad copters under varying condition s and environments and will follow all safety protocol of Air 2 Ground Imaging as well as guidelines of 14 C.F.R 61.51 (b) having the ability to safely operate the UAS in a manner consistent with the operating documents, including evasive and emergency

man euvers and maintaining appropriate distances from people, vessels, vehicles and structures as outlined. Specific Exemptions Requested Given the size, weight, speed, and limited operating area associated with the UA, we feel an exemption from 14 CFR 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 of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333).

Werequest an exemption from§ 45.23 Marking of the aircraft because the UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two

- inch lettering is difficult to place on such a sm all aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the word "Experimental" on its fuselage as required by § 45.29(f) so that anyone will see the markings.

Werequest an exemption from § 91.7(a) which prohibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable.Werequest an exempt ion from§§ 91.405(a), 91.407(a)(1 ), 91.409(a)(2) and

91.417(a) and (b) Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety precaution we will perform a preflight inspection of the UAS before ea ch flight as outlined in the attached operating documents.

Werequest an exemption from§ 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and given its size, this re gulation is inapplicable. Webelieve an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station.

Werequest an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraf t, but it allows helicopters to be operated at lower altitudes in certain conditions. W e will not operate our UAS above the altitude of 400 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus "provi ding a level of safety at least equivalent to or below those in relation to minimum safe altitudes." Given the size, weight, maneuverability, and speed of the UAS, an equivalent or higher level of safety will be achieved. Werequest an exemption from 

### § 91. 121 Altimeter settings as it is inapplicable since the UAS utilizes electronic GPS with a barometric sensor.

Werequest an exemption from 

### § 91.151 (a) Fuel requirements for flight in VFR conditions. The UAV is 100% electric and two low battery alerts are issued

- per the operating documents, the UAV will be landed at the first alert. Also, our flights will last only 8

- 12 minutes each, and the UAS has an automated function, which results in immediate landing when a low battery is detected. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, land the UA with 30% battery power remaining.

Public Interest Aerial videogra phy for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. By granting this exemption we would be ab le to provide this service at a much lower cost. Further, our small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. Additionally, the operation of our UAS will minimize ecolog ical damage and promote economic growth by providing information to companies looking to relocate or build in the metro areas we service.

Summary

Wewill comply with all of the following conditions and limitations should this grant of exemption 

### be provid ed:1) Operations will be limited to the following aircraft described in the operating

documents which is a quad

- rotor aircraft weighing less than 7 pounds:

DJI Phantom 3 Professional

Aircraft System. 2) The UAS will not be flown at an indicated airspeed exceeding 30 knots. 3) The UAS will be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be in feet AGL. 4) The UAS will be op erated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times. 5) All operations may utilize a visual observer {VO). The UA will be operated within the visual line of sight {VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the operating documents. 6) The operating documents will be accessible during UAS operations and made available to the Administrator upon request. Any revisions to the operating documents will be presented to the Administrator upon request. 7) Prior to each flight, the PIC will in spect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records. 8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry in the aircraft records. 9) The pre

-flight inspection section in the operatin g documents will account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 10) W e will follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

11) W e will carry out maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft record s, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service. 12) Each UAS operated will comply with all manufacturer Safety Bulletins. 13) An authorized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.14). The PIC will also meet the flight review requirements specified in 14 CFR

61.56 in an aircraft in which the PIC is rated on. 15) Prior to ope rations conducted for the purpose of aerial videography/cinematography and augmenting real estate listing videos (or similar operations), the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51 (b), 16) Prior to operations conducted for the purpose of aerial videography/cinematography and augmenting real estate listing videos (or similar operations), the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51 (b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations.

17) The PIC will not operate the UAS for the purpose of aerial videography/cinematography and augmenting real estate listing videos (or similar operations), unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51 (b), the ability to safely operate the UAS in a manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and st ructures. 18) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be conducted under visual meteorological conditions (VMC). 19) The UA will not operate within 5 nautical miles of an airport reference point as d enoted on a current FAA

- published aeronautical chart. 20) The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 21) If a UA loses communications or loses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 22) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 23) The PIC will not begin 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 30% battery p ower remaining. 24) Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission {FCC) or other appropriate government oversight agency requirements. 25) The docu ments required under 14 CFR 91.9 and 91.203 would be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request. 26) The UA will remain clear and yield the right of way to all manned aviation operations and activities at all times. 27) The UAS will not be operated by the PIC from any moving device or vehicle.28) The UA will not be operated over congested or densely popu lated areas.

29) Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. W e will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immedi ately 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 obje cts and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per 

### § 91.119(a).

30 ) All operations will be conducted over priva te or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

31) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Tran sportation Safety Board (NTSB) per instructions contained on the NTSB W eb site: www.ntsb.gov.

On behalf of Air 2 Ground Imaging. I would like to thank you for your consideration in granting this exemption. It will be an honor to hold this designation and I look forward to adding UAS video I photography offerings to my business portfolio.

Thank you for your consideration

Salvatore C Gibilisco Air 2 Ground Imaging 157 Fox Chase Drive, Delran, New Jersey 08075 609

- 864

- 0884