**James Dacri, AeroHiView**  **163 Madrone Ave Larkspur**  **, CA**  **94939 Telephone:**  **415**

**- 515** 

**- 7807**  **Email: jdac@pacbell.net** 

September 7 , 2015 U. S. Department of Transportation Docket Management System West Building Ground Floor, Room w12

- 140 1200 New Jersey

Avenue, SE Washington DC 20590

**RE: Exemption Request Section 333 of the FAA Reform Act** 
Dear Sir or Madam:

We respectfully

request exemption under Section 333 of the FAA Reform ACT and Part 11 of the Federal Aviation Regulations.

**Petitioner:** James Dacri, AeroHiView (AHV) 163 Madrone Ave Larkspur, CA 94939 Telephone: 415

- 515

- 7807 Email: jdac@pacbell.net
AHV intends to incorporate the use of sUASs for a variety of projects which may include but not be limited to project and construction management, inspections and monitoring; environmental review projects; aerial surveying; agricultural projects; educational and research projects; remote sensing projects, wildlife and forestry monitoring projects; aerial filmmaking, photography and real estate purposes; search and rescue, etc. **Specific Section(s) seeking exemption:**
14 C.F.R Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b)(2) 14 C.F.R. 91.109 14 C.F.R. 91.119**Specific Section(s) seeking exemption(cont.):**

14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) and (b) 14 C.F.R. 91.215 14 C.F.R. 91.104 through 91.417 **Extend of relief requested:**

To permit commercial operation of Small Unmanned Aircraft Systems (sUASs) for operations conducted within and under the conditions outlined herein or as may b e established by

the FAA as required b y S ection 333.
Said exemption would permit the operation of sUASs under controlled conditions in limited, predetermined and controlled airspace. Upon granting of this proposed exemption request, AHV would conduct commercial operations of sUASs me eting or exceeding all operational and safety requirements per Section 333.

**Public Benefit:**
1. Project and construction management, inspections and monitoring. The use of sUASs on construction sites may

improve the safety of workers, local residents and general public by assessing potential dangerous situations. F alls and injuries may b e reduced or eliminated through a more thorough review of the construction sites. In some cases, sUASs may reduce the reliance of helicopters or small aircraft to monitor said sites. This may improve safety as well as reduce environmental impact by reducing energy usage; 2. Environmental Review projects. The use of sUASs during the process of reviewing projects
as required by

2 4 C.F.R. 50.4, 58.5 and 58.6 would provide a more in

- depth Environmental Review of the project site as well as surrounding areas. Reliance of helicopters or small aircraft may

be eliminated; 3. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas may e liminate the use of helicopters or aircraft. This could provide a more cost effective, safer and more energy

efficient product; 4. Agricultural projects. Wildlife and Forestry projects. The use of sUASs could assist with surveying agricultural projects as well as wildlife and forestry p rojects by

providing information when problems occur, vermin infestation, fire hazards, etc.; 5. Remote Sensing projects. The use of sUASs could provide views and information for remote and inaccessible areas. This could promote worker safety a s well as reduce the reliance on helicopters and aircraft; 6. Educational and Research projects. The use of sUASs could provide information for said projects in a more cost effective and efficient manner than other available options7. Aerial filmmaking, photography and real estate purposes. The use of sUASs may provide a point of view previousl y unavailable through other means. They would be more cost effective, efficient and more safel y than helicopters and aircraft; and 8. Search and rescue. The use of sUASs may provide assistance to local law organizations during search and rescue missions. S UASs may reach areas unattainable or viewable with helicopters and aircraft. S UASs may be implemented quicker as time is of the essence during search and rescue operations. **Reasons why the exemption would not adversely affect sa fety or how the exemption would**  **provide a level of safety at least equal to the existing rule.** Proposed operations using sUASs provide increased safety enhancement especiall y when compared with helicopters and aircraft for the following reasons: 1. The sUASs will weigh less than ten (10) pounds; 2. Flights will be operated within the visual line of sight of the pilot; 3. Maximum total flight time for each operational flight will be thirty ( 30) minutes. F light times may

b e less than thirty

( 30) minutes as the UAS will continuously monitor battery reserve and return to the ground station with at least 20% battery power reserved; 4. Flights will be operated at an altitude of 200 feet AGL. F lights will never exceed 400 feet AGL; 5. Minimum crew for each operation wil l consist of the sUAS pilot and a Visual Observer; 6. A briefing will be conducted dail y b y all personnel working with said sUAS; 7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written consent will be required of all persons within 100 feet of flight operation; 8. Written and/or oral permission from relative property owners will be obtained prior to operating the sUAS; 9. All permits, permissions, etc. will be obtained from local government offices as required; 10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.); and 11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move verticall y and horizontally; 12. The sUAS will have the capability to return and land at the pre - determined location with the Security Perimeter should the sUAS lose communication or GPS signal during any operations; 13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies; 14. Operations will not be conducted over densely p opulated areas or heavily traffic highways;15. Operations will not be conducted within five (5 ) NM of an airport or heliport

AHV will abide b y all regulations including the following:

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness Certificates; 2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks; 3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations; 4. 14 C.F.R. 91.7 Civil aircraft airworthiness; 5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements; 6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests; 7. 14 C.F.R. 91.119 Minimum saf e altitudes: general; 8. 14 C.F.R. 91.121 Altimeter settings; 9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions; 10. 14 C.F.R. 91.203 Civil aircraft: Certifications required; 11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U .S. airworthiness certificates: Instrument and equipment requirements; 12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use; 13. 14 C.F.R. 91.401 Applicability; 14. 14 C.F.R. 91.403 General; 15. 14 C.F.R. 91.405 Maintenance required; 16. 14 C.F.R. 9 1.407 Operation after maintenance, preventive maintenance, rebuilding or alteration; 17. 14 C.F.R. 91.409 Inspections; 18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests and inspections; 19. 14 C.F.R. 91.413 ATC transponder tests and inspe ctions; 20. 14 C.F.R. 91.415 Changes to aircraft inspection programs; and 21. 14 C.F.R. 91.417 Maintenance records. **Privileges of exemption outside the United States.**
AHV may

wish to exercise the privileges of this exemption outside the United States should a contract with a governmental office require same. All required rules and regulations will be followed should this occur. **Equipment and Specifications.** Phantom 3 Professional**Aircraft** Weight (Including Battery And Propellers) 1280 g Diagonal Size (Including Propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Hover Accuracy Vertical: +/

- 0.1 m (when Vision Positioning is active) or +/

- 0.5 m Horizontal: +/

- 1.5 m Max Speed 16 m/s (ATTI mode, no wind) Max Altitude Above Sea Level 6000 m Operating Temperature 0°C to 40°C GPS Mode GPS/GLONASS

**Camera** Sensor Son y EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ ISO Range 100

- 3200 (video) 100

- 1600 (photo) Shutter Speed 8s

- 1/8000s Image Max Size 4000 x 3000 Still Photography Modes Single Shot Burst Shooting: 3/5/7 shots Auto Exposure Bracketing (AEB): 3/5 Bracketed Frames at 0.7EV Bias Ti me - lapse Video Recording Modes **Phantom 3 Professional** UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 FHD: 1920x1080p 24/25/30/48/50/60HD: 1280x720p 24/25/30/48/50/60 **Phantom 3 Advanced** FHD: 1920x1080p 24/25/30/48/50/60 HD: 1280x720p 24/25/30/48/50/60 Supported SD Card Ty

pes Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required Max Bitrate Of Video Storage **Phantom 3 Professional** 60 Mbps **Phantom 3 Advanced** 40 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4, MOV (MPEG

- 4 AVC/H.264) Operating Temperature 0°C to 40°C

**Gimbal** Controllable Range Pitch

- 90° to +30° Stabilization 3

- axis (pitch, roll, yaw)
**Vision Positioning** Max Velocity Less than 8 m/s (when 2 m above ground) Altitude Range 30 cm

- 300 cm Operating Range 30 cm

- 300 cm Operating Environment Surface with clear pattern and adequate lighting (Lux > 15)

**Remote Controller** Operating Frequency 2.400 GHz

- 2.483 GHz Max Distance 2000m (outdoors and unobstructed) Video Output Port USB Operating Temperature0°C

- 40°C Battery 6000 mAh LiPo 2S Mobile Device Holder For tablet or phone Receiver Sensitivity

(1%PER)

- 101 dBm ±2 dBm Transmitter Power (EIRP) FCC: 20 dBm CE: 16 dBm Working Voltage 1.2 A @7.4 V
**Battery Charger** Voltage 17.4 V Rated Power
**Phantom 3 Professional**  100 W **Phantom 3 Advanced** 57 W
**Intelligent Flight Battery** Capacity 4480 mAh Voltage 15.2 V Battery Ty pe LiPo 4S Energy 68 W h Net Weight 365 g Max Flight Time Approximately 23 minutes Operating Temperature

- 10°C to 40°C Max Charging Power 100 W
**App / Live View** Mobile App DJI GO EIRPAlso plan to buy the DJ I Inspire 1 in the near future. Please feel free to contact our office if there are any additional questions or concerns.
Sincerel y,

James Dacri 100mW

Live View Working Frequency 2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and mobile device) Latency 220m s (depending on conditions and mobile device) Required Operating S ys tems iOS 8.0 or later Android 4.1.2 or later Recommended Devices iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi

- Fi + Cellular, iPad mini 2, iPad mini 2 W i Cellular, iPad mini 3, and iPad mini 3 W i

- Fi + Cellula r. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus Android: Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend M Nubia Z7 mini, SONY Z3 EXPERIA, MI 3, MI PAD *Support for additional Android devices available as testing and development continues.