Jeffrey W . Bopp May 4, 2015

225 Lockwood Dr. Lexington, SC 29072 Cell (803) 381-1561 Email: jbopp22@yahoo.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 1) Phantom 2 Vision+ User Manual V1.8 2) Phantom 2 Vision Plus (Quick Start Guide) 3) Phantom pilot training guide V1.1

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the matter of the peti tion of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

– 2014

– 0508 in the matter of the petition of AD VANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA ’ s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Moderniz ation and Reform Act of 2012 , I Jeffrey W. Bopp, referred to hereafter as the petitioner, request exemption fr om the following sections of Title 14, Code of Federal Regulations §§

61.113(a) ; 61.113(b) ; 91.119(c) ; 91.121 ; 91.151(a) ; 91.405(a) ; 91.407(a)(1) ; 91.409 (a)(1) ; 91.409(a)(2) ; 91.417(a) & (b) ; In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administrati on (FAA) for the purposes of aerial photography, cinematography, videography, and other flight op erations that could be performed safely and more cost effectively with the use of small UAS at low altitude within th e U.S. national airspace system as compared to a manned aircraft. Opera tions will be performed only at the request of and with the authorization and permission of clie nts or their authorized agents in order to

facilitate commerce and raise awareness of the be neficial uses of small unmanned air systems.

So long as such operations are conducted w ithin and under the conditions outlined herein or as may be established by the FAA as require d by Section 333. The conditions identified and proposed by the petitioner are drawn from references 1-3.The FARs The petitioner seeks exemption from the above mentioned FARs for the following

reasons ; 61.113(a) & (b) ; The petitioner requests relief in order to f acilitate the utilization of an experienced UAS operator with the addition of a trained observer. All pre-flight inspection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely integrati ng civil UAS operation in the National Airspace System. 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may re quire that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption a nd clarification concerning the terms “ congested areas ” and

“ densely populated ” . The petitioner requests waiver for th is condition to allow reasonable and responsible operations in areas of su bdivisions and neighborhoods if required. The petitioner will primarily operate the UAS between ground level and 200 feet. The UAS will be operated over designated properties with the owner ’ s consent and while maintaining a safe distance from persons. The petitioner will compile flight data from the logs. This data may assist the FAA in development of regulations fo r commercial operations in low-risk, controlled

environments.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for

altitude information. 91.151(a) As discussed in Exemption 11136 (ADV ANCED AVIATION SOLU TIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery pow er management. Those documents contain a

condition in which the PIC will initiate a landi ng procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR

conditions was reasonable. 91.405(a) ; 91.407(a)(1) ; 91.409 (a)(1) & (2) ; 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner ’ s operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficien t to ensure that safety woul d not be adversely affected.The UAS The DJI Phantom 2 vision plus is a highly succ essful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring unit (I MU) with integrated barometric sensor augmented with global positioning system (GPS ) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified ra dio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strengt h, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has fail safe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will wa rn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termin ation of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that fl ights will usually last

less than 12 minutes. More informati on is available in attachment 1.

Risk mitigation The petitioner has reviewed FAA exemptions reference ’ s 1-3 Conditions and Limitations section and believes that the procedures specifie d therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performan ce of routine inspections before each flight, maintaining flight and maintenance logs to r ecord time on failure prone components. These

documents will be made available to the FAA a nd SoT to assist in future implementation of safety standards and regulations. The petiti oner will only operate the UAS over designated properties with the owner ’ s consent. Flight plans will be predetermined to limit the UASs flight time and limit safety concerns. Th e petitioner will take into a ccount distance from persons and potential flight obstacles prio r to operating the UAS. UAS operation will always be within

VLOS of the PIC and the observer.

Public interest
Use of the UAS in lieu of a manned aircra ft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to facilitate commerce could lead to economic grow th. Operations for this petition will enable service for property owners or their design ees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography/pho tography. Aerial photography is a valuable marketing tool that can lead to increased co mmerce and enhance personal photography. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide client s with photographic data for these purposes on a‘ for hire ’ basis acting as an independent contractor. A vi sual observer will be utilized. Flight data including UA flight time, Contro l Unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via traditional means or other means as required.

Conclusion The petitioner is requesting this exemption for the purposes of “ aerial photography, cinematography, videography, inspec tions and other flight operations ” . The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the futu re without the long turnaround tim e associated with additional exemptions. The petitioner's business model is based on the idea of offe ring ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. The petitioner has refrained from engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the capability to offer those services while remainin g in compliance. The petitioner has 7 years of experience in the radio control model aircraft hobby.

Respectfully submitted

Jeffrey W. Bopp