# Gabriel Ryan Lowry 1613 Laurel Lane Prescott,Arizona 86301• Phone: 928-533-6881 July 15, 2015 U.S. Department ofTransportation Docket Management System 1200 New JerseyAve. S.E. Washington , D.C. 20590 Dear Sir or Madam: 

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Pursuant to Section 333 ofthe Federal Aviation Administration (FAA) Modernization and Reform Act of2012 and 14 C.F.R. Part 11 , Mr. G. Ryan Lowry files this petition for exemption as an operator of Small Unmanned Aircraft Systems (UAS) used for remote sensing to support aerial data collection , specifically photography and video capture of commercial and residential real estate properties. Mr. Lowry seeks an exemption from the Federal Aviation Regulations (FARs) listed in this petition to allow commercial operation of its UAs, so long as the operations are conducted under the conditions specified within this petition or as may be required by the FAA in granting this petition. BACKGROUND Approval ofthe exemption for Mr. Lowry will allow commercial operation ofthe DJI Phantom 1 , and DJI Inspire 1 (model specifications listed below). The Unmanned Aircraft (UA) identified in this exemption petition are small , battery-powered aircraft,that weight less than 12 lbs. , including battery and sensing payload.The operation ofthe UAs in the photographic and video sensing mode, allow for a level ofsafety greater than that provided by larger manned aircraft, including helicopters and fixed wing aircraft that carry flammable fuel and operate at an above ground level (AGL) altitude that would increase risk to the aircraft operator as well as personnel and property on the ground. In addition,with a small payload and maximum flight time between 15 to 18 minutes,these UAs offer little to no risk to national security. UNMANNED AIRCRAFT (UA) SPECIFICATIONS 1. DJI Phantom 1 • Take-OffWeight- <1200g • Hovering Accuracy (GPS)- Vertical: 0.8m ; Horizontal: 2.5m

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• Max Ascent/Descent Speed- 6m/s • Max Flight Velocity- 1Om/s • Diagonal Distance (Motor Center to Motor Center) - 350mm • 12 to 15 minute maximum flight time depending on battery • Remote Controller (FCC approved portable handheld)- 2.4GHz ISM o 

### Control Channels - 7 o 

### Communication Distance - 1DOOm o 

### System provides a fail-safe feature that allows the aircraft to return to the launch point and land automatically in the event the command and control signal is lost orthe battery has reached a pre-determined threshold. 2. DJI Inspire 1 • Take-OffWeight- 2935g • Hovering Accuracy (GPS) -Vertical: 0.5m; Horizontal: 2.5m • Max Ascent Speed- 5 m/s • Max Descent Speed - 4 m/s • Max Speed - 22 m/s (ATTl mode, no wind) • Max Flight Time- 18 minutes • Dimensions- 438 X 451 X 301 mm • Remote Controller (C 1) o 

### Operating Frequency- 5.725-5.825 GHz; 2.400-2.483 GHz o Transmitting Distance - 2km o Output Power - 9 W

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# • • GROUND CREW • Pilot in Command (PIC). The pilot in command will have at least a Sport Pilot Certificate or higher, and valid U.S. Drivers License (DL). • Visual Observer (VO) if required. The visual observer will provide additional situational awareness during flight operations. Flight Operation Parameters • The Unmanned Aircraft System will weigh less than 55 lbs. • Flights will be operated within visual line ofsight (VLOS) ofthe PIC and VO (if a VO is required). • Flights will be conducted during day Visual Flight Rules (VFR) conditions • Flights will be operated at an altitude limit of

### 200 feet Above Ground Level (AGL) as indicated in the "blanket COA" unless a specific COA is obtained. • Operations in the vicinity ofairports and/or heliports will be conducted according to the "blanket COA" as follows: o 5 nautical miles (NM) from an airport having an operational control tower; or o 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or o 2 NM from an airport without a published instrument flight procedure or an operational tower; or o 2 NM from a heliport with a published instrument flight procedure • PIC will be a U.S. certificated airman with at least a Sport Pilot Certificate and valid U.S. Drivers License. • PIC will have logged, as a minimum, at least 

### 10 hours in the operations ofthe UAS aircraft specified with this exemption petition . • Permission will be obtained from the property owner ofthe aerial photography/video capture sight. 3

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• Flight operations will not be conducted on board a moving vehicle PREFLIGHT OPERATIONS • Preflight weather briefing including current and forecast weather and Notice to Airmen (NOTAMs) pertinent to the intended flight location.This will be used by PIC to determine whether proposed flight operations can be conducted safely under day VFR conditions and in accordance with the pertinent COA. • Preflight inspection of UA to determine that aircraft is airworthy for the proposed flight operations. This will include, as a minimum, inspections ofairframe, propellers, on-board aircraft and remote controller batteries, and a satisfactory preflight test offlight controls and pertinent switches. • Preflight visual inspection ofthe geographical area to be surveyed/photographed to determine location ofstructures,foliage,trees, and other natural or man-made obstacles that would present a hazard to the proposed flight. • Prior to the proposed flight,the PIC will have received permission from the owner or designee ofthe property to be surveyed/photographed to conduct the aerial survey ofthe property. PETITIONER'S CREDENTIALS • FAA COMMERCIAL PILOT CERTIFICATE o Date of Issue: 11/4/2004 o Ratings: Airplane Single/Multiengine Land ; Instrument Airplane • Arizona Drivers License o Class D; Expires 06/18/2042 DOCUMENTATION The following documents are attached to support this petition: • DJI Phantom 1 Quick Start Manual (V. 1 .7) • DJI Inspire 1 Users Manual (V. 1.2)

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# • SECTIONS OF 14 C.F.R. FROM WHICH PETITIONER SEEKS AN EXEMPTION A. 14 C.F.R. Part 91.7(a) Civil AircraftAirworthiness The UAs described within this petition will not be issued an airworthiness certificate (in accordance with 14 C.F.R. Subpart H) , and decisions established by previous Section 333 exemptions for small, unmanned UAS. The PIC will determine the airworthy condition prior to each flight. The petitioner seeks relieffrom this FAR. B. 14 C.F.R. Part 91.119(c) Minimum Safe Altitudes Over Congested and Other Areas The UAS operation will be conducted at or below 200 feet AGL (unless a higher limit COA is obtained) in a well-defined area where personnel and structures will not be exposed to UAS operations without consent. The petitioner seeks relieffrom this FAR. C. 14 C.F.R. Part 91.121 Altimeter Settings The UAS identified in this petition does not have a barometric altimeter but maintains its altitude by utilizing GPS equipmenttogether with static pressure sensor. The petitioner seeks relieffrom this FAR. D. 14 C.F.R. Part 91.151 (a) Fuel Requirements for Flight in VFR Conditions The UAs described within this petition will fly for a maximum of 18 minutes due to onboard aircraft battery restrictions. The UAs have telemetry data that provides the PIC with remaining battery power in the aircraft that will allow the operator to terminate flight operations when the battery level reduces to a pre-determined 25 percent. The petitioner seeks relieffrom this FAR. E. 14 C.F.R. Part 91.405(a) Maintenance Required ; 14 C.F.R. Part 91.407(a)(1) Operation after Maintenance, Preventative Maintenance, Rebuilding or Alteration ; 14 C.F.R. Part 91.409(a)(1) and (2) Inspections; 14 C.F.R. Part 91.417(a) and (b) Maintenance Records These sections apply to aircraft that have an airworthiness certificate and since the UAs described within this petition will not have an airworthiness certificate,these sections are not applicable to this proposed UAS. In addition,the FAA has issued a previously exemption to these regulations in Exemption No. 11062. The petitioner seeks relieffrom these FARs. 

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SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER Petitioner: Gabriel Ryan Lowry Sections of 14 C.F.R. Affectedin Petition: Part 91.7(a); Part 91 .119(c); Part 91.121; Part 91.151 (a); Part 91.405(a) ; Part 91.407(a)(1), Part 91.409(a)(1); Part 91.417(a) and (b) Description ofReliefSought: Mr. Gabriel Ryan Lowry seeks relieffrom the requirements of 14 C.F.R. Part 91.7(a); 14 C.F.R. Part 91.119(c); 14 C.F.R. Part 91.121; 14 C.F.R. Part 91.151(a); 14 C.F.R. Part 91.405(a); 14 C.F.R. Part 91.407(a)(1); 14 C.F.R. Part 91.409(a)(1) ; 14 C.F.R. Part417(a) and (b) to operate small unmanned aircraft systems (UAS) for the purpose of real estate aerial photo and video data collection. Respectfully Submitted ,

Gabriel Ryan Lowry Petitioner/Owner of UAS

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