FIR~L!:::I September 16, 2015 

TO: Federal Aviation Administration 

FAA Logistics Center 

AML-30 

PO Box 25082 

Oklahoma City, OK 73169 

From: Matt D. Kee 

James D. Griffin, Ill 

Firefly UAV Services, LLC 

8515 Rigby Ct. 

Humble TX, 77346 

(713)-542-2271 

Matt.kee@fireflyuav.com 

RE: Petition for Exemption 14 CFR 11.81 

Dear Sirs: 

We, the owners of Firefly UAV Services, LLC, hereby submit a petition to receive an 

exemption or waiver from 14 CFR 11.81 Section 333 UAS. We currently own a DJI 

Inspire 1 quadcopter. 

Firefly UAV Services is seeking relief from section 333 in order to operate a UAS on a 

commercial level. The reason for this request is to take professional aerial photography 

and Videography for Real Estate agents, home builders, property development 

companies, and property owners. Because our business specifically provides these 

entities with professional videography, it is imperative to provide our clients with the 

proper tools necessary to show each property they have for sale. These professional 

pictures and videos can also be beneficial in defining property value. 

In the sale of Real Estate prospective buyers are requiring more information in order to 

make informed decision about the property they are considering. As property values go 

Firefly UAV Services, 

www.FireflyUAV.com 

Matt.Kee@FireflyUAV.com 

713-542-2271 (] LLC 
FIR~(_~ up, it is necessary for prospective buyers to see what 

they are buying, and adequately asses the value of the 

property. 

In years past, in order to get good aerial photos of a property, a manned aircraft was 

required to fly above the property. The use of a UAS to do that job will increase the 

safety of the public by reducing the risk of a large aircraft crash, creating a safer 

environment by not adding toxins to the air, reducing the number of large aircraft in our 

ground flights without disturbing the land or plant life. The use of a UAS will also allow 

prospective buyers of the property views of lower elevation terrain that wasn't possible 

with larger aircraft. 

The following are the specifications of the UAS to be used. 

Hardware: 

* Size: 11 .9 by 17.2 by 17.8 (HWD) 

* Weight: 2935 g including battery 

* Transmitter operating frequency: 5. 725 GHz- 5.825 GHz or 2.400 GHz2.483 GHz 

* Travel Speed of up to: 50 mph 

* Communication Distance: 2 Km 

*See http://www.dji.com/product/inspire-1/download for additional 

information 

Software: 

* GPS auto-pilot system for position holding provides altitude lock along 

with stable hovering; 

* GPS return to take off if communication is broken or low battery is 

detected 

* See http://www.dji.com/product/inspire-1 /download for additional 

information 

Based on an article published on operational limitations at the following web address 

https://www.faa.gov/regulations policies/rulemaking/media/021515 sUAS 

Summary. pdf we will meet or exceed those limitations with the following specifications 

at which we will be flying the UAS. 

Firefly UAV Services, 

www.FireflyUAV.com 

Matt.Kee@FireflyUAV.com 

713-542-2271 (5} LLC 
F:IREJC...!:::J * Based on the equipment listed above, we will operate 

a UAS that weighs less than 81bs; 

* The VLOS (Visual Line of Sight) rule for our company 

is limited to an up and down motion no more than 300-500 feet of controller and 

operator; 

*Due to the close proximity of the flights, the UAS will be able to be seen at all 

times without any additional monitoring equipment other than standard human eye 

VISIOn; 

* Flight of the UAS will be done with the permission of all parties associated with 

the property that will be filmed and at no time will we fly the UAS directly over a 

person without giving prior knowledge and permission; 

* The Flight of the UAS will not be performed during non-daylight hours and will only 

be flown in conditions that allow the UAS to be seen by the operator at all times; 

* The limitation of the UAS to be flown at no more than 35m ph. We find that it is not 

necessary to fly it more than 15-20mph for production purposes; 

*The UAS will not be flown any higher than 300FT above the surface it is being 

flown over or Class G operations; 

*The UAS will be inspected prior to every flight for safe operation including, but not 

limited to battery condition, operations of electric motors, GPS system, IR 

Controller, propellers, and Wi-Fi connection between UAS and Controller; 

* Based on Software installed, the UAS will not be flown within a Smile radius of any 

commercial airstrip; 

* Safety will be priority over footage. If any flight will pose a safety hazard to any 

persons, animals, or the environment the flight will be immediately cancelled until 

such time can be deemed safe; and/ or 

* Operators will maintain a GPS signal with the UAS at all times during the flight. If 

connection is broken the equipment's built in GPS system will return the UAS to the 

initial take off point and land it safely. If that system is broken for any reason an 

emergency land will take place lowering the UAS to the ground. 

*See http://www.dji.com/product/inspire-1/download for additional information 

Firefly UAV Services, 

www.FireflyUAV.com 

Matt.Kee@FireflyUAV.com 

713-542-2271 Cl LLC 
FIR~ C..~ Furthermore, by following the above operational 

limitations that we have imposed on flights, we will not 

be posing any kind of harm to the public, environment, 

or to wildlife. 

Since Firefly will meet or exceed the operational limitations that are set forth to be 

enforced, I hereby request that we be granted an exemption. Please contact me with 

the above contact information if you need any further documents. 

Owner 

Firefly UAV Services, 

www.FireflyUAV.com 

Matt.Kee@FireflyUAV.com 

713-542-2271 ~ 

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Owner 

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