U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12 - 140 1200 New Jersey Avenue, SE Washington, DC 20590

Michael J. Murphy 15 Walling Avenue Oneonta, NY 13820 607 - 267 -9123 mjmoneonta@gmail.com Subject: Petition for Exemption to Operate Phamton 2 Plus sUAS for the Purpose of Real Estate Photography, Sporting Events Photography and Public Events Photography. Dear Sir or Madam, Michael J. Murphy (MJM) is requesting exemption from the Federal Aviation Administration for certain Federal Aviation Regulations so that I may use a sUAS (small Unmanned Aircraft System) in conducting the business of aerial photography in the real estate market, sporting event filming for coaching evaluations, and for filming public events for clients. The sUAS I will be using is the DJI Phamton 2 plus Quadcopter. The DJI Phamton 2 plus has safety features that include Return Home Automatically if the sUAS should exceed its control range or if there is a failure in the control module and a No Fly Zone warning feature that alerts the PIC and VO if the sUAS gets to close to an airport or restricted airspace. The sUAS will return to its launch point automatically when it determines the battery levels are too low. The Phantom 2 plus has a take -off weight of 1250g and operates at 5.8GHZ. Accent and decent speed is 6m/s. Maximum flight speed is 10m/s. **Re: Request for Exemptions Pursuant to Section 333** P art 11, CFR –Part 21 -Subpart H; Part 36; 45.23; Part 6 1.113(a)&(b); 91.7(a); 91.9; 91.103; 91.109; 91.119; 91.121; 91.151(a) - (1); 91.203; 91.405(a) 14CFR – Part 21 Subpart H – Airworthiness Certificate, Certification Proceedures 14CFR – Part36 – Noise Regulations 14CFR – 45.23 – Display Markings14CFR – Part 61.113(a)&(b) – Certifications for Instructors and Pilots

14CFR – 91.7 – Civil Air Worthiness 14CFR – 91.9 – Flight Manuals and Markings Requirements 14CFR – 91.103 – Preflight Actions 14CFR – 91.109 – Flight Instructions 14CFR – 91.119 – Minimum Safe Altitudes 14CFR – 91.121 – Altimeter Settings 14CFR – 91.151 – VFR Requirements for Fuel 14CFR – 91.203 – Certificates Required for Civil Aircraft 14CFR – 91.405(a) – Maintenance Required

14 CFR Part 21 -Subpart H – (MJM) asks for exemption from an Airwort hiness Certificate because of the size, weight and speed of the sUAS in comparison to manned aircraft makes the risks involved negligible in comparison. 14 CFR Part 36 – (MJM) asks for exemption from noise standards due to the sUAS size and low noise impact. 14 CFR 45.23 – (MJM) asks for exemption from the marking requirements for aircraft. The size of the sUAS will not accommodate the minimum 2” letters. 14 CFR Part 61.113 (a)&(b) – (MJM) asks for exemption from the certification requirements for pilots. While the sUAS will only be operated over private property with the consent of the property owner it is my belief that my 40 plus hours of actual flight time and safe operation of the sUAS and with the full understanding of the FAA Rules and Regulations governing the use of sUAS is sufficient to operate it safely in the NAS. 14 CFR 91.7 – (MJM) asks for exemption from this FAR for the same reasons being requested for Part 21

– Subpart H. 14 CFR 91.9 – (MJM) asks for exemption from this FAR for the same reasons being requested for Part 21 - Subpart H, as placards and on - board flight manuals are impractical on a sUAS. 14 CFR 91.103 – (MJM) asks for exemption from this FAR as it pertains to manned aircraft. All appropriate pre -flight actions will be taken an d documented with the sUAS. 14 CFR 91.119 – (MJM) asks for exemption from Minimum Safe Altitudes over various areas in order to accomplish the intended mission. 14 CFR 91.121 – (MJM) asks for exemption from this FAR as the sUAS does not have an altimeter that this FAR refers to. The Phantom 2 Plus has a flight ceiling of 300’ AGL monitoring will be monitored by the PIC.14 CFR 91.203 – (MJM) asks for exemption this FAR as it requires Airworthiness Certificate. (MJM)

requested relief from an Airworthiness Certificate in Part 21 -Subpart H. sUAS will be serviced annually by a DJI certified service center to ensure proper functioning. 14 CFR 91.207 – (MJM) asks for exemption from operation our sUAS with an Emergency Locator Transmitter. My sUAS will always be flown within VLOS rules. 14 CFR 91.405 – (MJM) asks for exemption from FAR as all maintenance will be done by PIC and DJI certified service center as recommended by manufacturer. My mission for safe operation in the NAS will be to always stay below 300’ ce iling, operate only within VLOS by PIC and a VO if required and to endo all flights when battery capacity reaches below 25%. Additionally (MJM) will not operate the sUAS in public places or above crowded areas without flight preplan and VO at each end of flight pattern. Before we deploy the sUAS we will stand signs at each end of the operating area to alert the public that aerial photography is taking place. Prior to each flight the PIC and the VO will examine the flight area for overhead power lines, trees, and any other obstacles that could threaten public safety. Weather conditions will be the final determining factor before each flight. I will be the PIC, I have over 40 hours of flying time with the DJI Phantom 2 Plus. The VO has over 15 hours of observation time with the DJI Phantom 2 Plus and over 10 hours flying time. The sUAS will be flown only during daylight hours and under VLOS rules. (MJM)’s goal is to provide quality Aerial Photographic and Video services primarily to Real Estate Agents to enhan ce their business model and professionalism while adhering to all FAA rules for safe flight. Before and after each flight the PIC and VO will visually inspect all rotor blades, electrical connections, battery conditions and levels and test the communicatio n link between the sUAS and the controller. It is my belief that the use of the sUAS in place of manned aircraft greatly increases the safety of the general public. My sUAS is compact, lightweight, carries NO flammable fuel and has not humans on board. Cou pled with the sUAS relatively slow airspeeds and that it is being operated within VLOS and under 300’ AGL by a qualified PIC and VO I feel that the risks of using a sUAS to conduct aerial photography have been greatly reduced. Thank you for your considera tion Respectfully, Michael J. Murphy