ll ll'l\ I l1S

1O5 So. f6il'Street

Arnes, lcwa 50010

(515) 233-4450

January 8, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Pursuant to Section 333

Dear Mr. Pappas,

I a m seeking relief from the following 14 CFR's:

t. 91.7(a)

2. 91.119(c)

3. 91,.121

4. 91.151(a)

s. 91.aos(a)

6. s1.407(a)(1)

7. s1.a0e(a)(1) and (2)

8. el.atG) and (b)

I would like to operate the PHANTOM 2 Vision+ quad-copter unmanned aircraft system (UAS) in Central

lowa to conduct aerial videography and cinematography to enhance academic community awareness

for those individuals and companies unfamiliar with the geographical layout of Central lowa and

augment real estate listing videos.

I have been a CPL since 2004 with over 3,000 hours of Flight Time and currently hold a First Class

medical certificate. I also have held an active CFI license since 2004. Over the last nine years, I oversaw

flight operations for an aerial mapping company using fixed-wing aircraft. Currently, I am employed

with a real estate services business called Hunziker Companies with hopes to utilize a UAS. Over the

past two years, I have also been practicing with a rotorcraft UAS and have amassed an estimated 50

hours of Flight Time.

Below are the regulations I am seeking relief from and reason:

91..7(al - I believe that since no FAA regulatory standard exists for determining airworthiness of the UAS,

the regulation is inapplicable.
91.119(c) - Operations will need to occur at altitudes under 300 feet and closer than 500 feet to persons

or objects.

91'.121' -The system has a barometric altimeter and GPS derived altitude capabilities while the FAA

requires any altitude reported to ATC to be in feet AGL.

91.151(a) - The system does not have the capabilities to adhere to this regulation.

91.a05(a) - This section doesn't pertain to a UAS.

91.a07(a)(1) - This section doesn't pertain to a UAS.

91.409(a)(1) and (2)-This section doesn't pertain to a UAS.

9t.al7@) and (b) - This section doesn't pertain to a UAS.

I would be happy to comply with the following conditions:

L) Operations authorized by this grant of exemption are limited to the following aircraft described in the

operating documents which is a quad-rotor aircraft weighing less than 3 pounds: PHANTOM 2 Vision+

Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petition or a

petition to amend this grant.

2)The UA may not be flown at an indicated airspeed exceeding 30 knots.

3) The UA must be operated at an altitude of no more than 300 feet above ground level (AGL), as

indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be

in feet AGL.

4) The UA must be operated within visual line of sight (VLOS) of the Pilot tn Command (ptc) at all times.

This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses,

as specified on the PIC's FAA-issued airman medical certificate.

5) All operations must utilize a visual observer (VO). The UA must be operated within the visual line of

sight (VLOS) of the VO at all times. The VO may be used to satisfy the VLOS requirement as long as the

PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times.

The PIC must be designated before the flight and cannot transfer his or her designation for the duration

of the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating

documents.

6) The operating documents and this grant of exemption must be accessible during UAS operations and

made available to the Administrator upon request. lf a discrepancy exists between the conditions and

limitations in this exemption and the procedures outlined in the operating documents, the conditions

and limitations herein take precedence and must be followed. Otherwise, the operator must follow the

procedures as outlined in its operating documents. The operator may update or revise its operating

documents. lt is the operator's responsibility to track such revisions and present updated and revised
documents to the Administrator upon request. The operator must also present updated and revised

documents if he petitions for extension or amendment to this grant of exemption. lf the operator

determines that any update or revision would affect the basis upon which the FAA granted this

exemption, then the operator must petition for amendment to its grant of exemption. The FAA's UAS

lntegration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the

operating documents.

7) Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. lf the

inspection reveals a condition that affects the safe operation of the UAS, the UAS is prohibited from

operating until the necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the preflight inspection. All

maintenance and alterations must be properly documented in the aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts

the functionaltest flight must make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents must account for all discrepancies, i.e.

inoperable components, items, or equipment, not already covered in the relevant sections of the

operating documents.

10) The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements.

11) The operator must carry out its maintenance, inspections, and record keeping requirements, in

accordance with the operating documents. Maintenance, inspection, and alterations must be noted in

the aircraft records, including total flight hours, description of work accomplished, and the signature of

the authorized person returning the UAS to service.

12) Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

13)The authorized person must make an entry in the aircraft record of the corrective action taken

against discrepancies discovered between inspections.

14) UAS operations must be conducted by a PIC possessing at least a private pilot certificate and at least

a current third-class medical certificate. The PIC must also meet the flight review requirements specified

in L4 CFR 61".56 in an aircraft in which the PIC is rated on his or her pilot certificate.

15) Prior to operations conducted for the purpose of aerial videography/cinematography and

augmenting real estate listing videos (or similar operations), the PIC must have accumulated and logged,

in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft

pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior documented flight

experience that was obtained in compliance with applicable regulations may satisfy this requirement.

Training, proficiency, and experience-building flights can also be conducted under this grant of

exemption to accomplish the required flighttime. However, said training operations mayonly be
conducted during dedicated training sessions. During training, proficiency, and experience-building

flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR

91..1.r9.

16) Prior to operations conducted for the purpose of aerial videography/cinematography and

augmenting real estate listing videos (or similar operations), the PIC must have accumulated and logged,

in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and

modelof the UAS to be used in operations underthe exemption; 5 hours make and modeltime may be

included in the 10 hours of multi-rotor time prescribed above. The PIC must accomplish 3 take-offs and

landings in the preceding 90 days (for currency purposes). Training, proficiency, experience-building, and

take-off and landing currency flights can be conducted under this grant of exemption to accomplish the

required flight time and 90 day currency. However, said training operations may only be conducted

during dedicated training sessions. During training, proficiency, and experience-building flights the plC is

required to operate the UA with appropriate distances in accordance with 14 CFR 91.11-9.

17) The operator may not permit the PIC to operate the UAS for the purpose of aerial

videography/cinematography and augmenting real estate listing videos (or similar operations), unless

the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely

operate the UAS in a manner consistent with how the UAS will be operated under this exemption,

including evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

18) UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be

conducted under visual meteorological conditions (VMC).

19)The UA may not operate within 5 nautical miles of an airport reference point as denoted on a

current FAA-published aeronautical chart.

20) The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a

cloud or when visibility is less than 3 statute miles from the PlC.

21) lf the UA loses communications or loses its GPS signal, it must return to a pre-determined location

within the planned operating area and land or be recovered in accordance with the operating

documents.

22|The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance

with the operating documents.

23) The PIC is prohibited from beginning a flight unless (considering wind and forecast weather

conditions) there is enough power to fly at normal cruising speed to the intended landing point and land

the UA with 30% battery power remaining.

2a) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also
require the operatorto request a Notice to Airman (NOTAM)not more lhan72 hours in advance, but

not less than 48 hours prior to the operation.

25)All aircraft operated in accordance with this exemption must be identified by serial number,

registered in accordance with 14 CFR parl47, and have identification (N-Number) markings in

accordance with 1-4 CFR part 45, Subpart C. Markings must be as large as practicable.

26) Before conducting operations, the radio frequency spectrum used for operation and control of the

UA must comply with the Federal Communications Commission (FCC) or other appropriate government

oversight agency requirements.

27) The documents required under l-4 CFR 91.9 and 91.203 must be available to the PIC at the Ground

Control Station of the UAS any time the UAS is operating. These documents must be made available to

the Administrator or any law enforcement official upon request.

28)The UA must remain clear and yield the right of way to all manned aviation operations and activities

at all times.

29) The UAS may not be operated by the PIC from any moving device or vehicle.

30) The UA may not be operated over congested or densely populated areas.

31) Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels,

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons

remain under such protection. lf a situation arises where nonparticipating persons leave such protection

and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the

risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PlC, VO, operator trainees or essential persons do not present an undue

hazard to those persons per 5 91.119(a).

32) All operations shall be conducted over private or controlled-access property with permission from

the land owner/controller or authorized representative. Permission from land owner/controller or

authorized representative will be obtained for each flight to be conducted.

33)Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the

operational area as defined by the applicable COA must be reported to the FAA's UAS lntegration Office

(AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
Along with this petition, I am submitting the PHANTOM Flying Flow Chart, PHANTOM Quick Start

Manual and the PHANTOM 2 Vision+ User Manual.

lf more information or documentation is needed to approve this exemption, please contact me at

515.239.8676.

Thank you for your consideration,

Crftrt

rustinR.Dodge h

Development Coordinator

Hunziker Companies