# 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 amseeking 

### relief

### fromthe 

### 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 2Vision+ 

### 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 

### withthe geographical 

### layout of Central 

### lowa and 

### augment real 

### estate listing videos.

I have been a CPL since 2004

### with over 3,000 hours 

### of FlightTime and 

### currently hold a First Class medical 

### certificate. Ialso have held an active CFI license since

### 2004. Over

### the last nine years, Ioversaw 

### flight operations 

### for an 

### aerial mapping 

### company using 

### fixed-wing 

### aircraft. Currently, Iam 

### 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 Iam 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 2Vision+ 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 alltimes. This requires 

### the PIC

### to be able

### to use human 

### vision unaided by any device 

### otherthan corrective lenses, asspecified on

### the PIC's FAA-issued 

### airman medical 

### certificate. 5)All 

### operations must utilize avisual 

### 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 alltimes. The PIC 

### must be designated 

### beforethe 

### flight and 

### cannottransfer 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 adiscrepancy 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 

### followthe 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 ofwork 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 dedicatedtraining 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 dedicatedtraining 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

### forthe 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 

### orwhenvisibility 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

### tothe 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

### requirethe 

### 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 CFR91.9 and 91.203 

### must be available 

### to 

### the PICat

### the Ground 

### Control Station 

### of

### the UASany

### 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 

### ofthe 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 

### ofthe operational area as

### defined by

### the applicable COA 

### must be 

### reported 

### tothe FAA's UAS 

### lntegration Office (AFS-80)

### within 24 hours. Accidents 

### must be 

### reported 

### tothe National 

### Transportation Safety Board (NTSB) 

### per instructions contained on 

### the NTSB Web site: 

### www.ntsb.gov.Along 

### with this 

### petition, Iam 

### submitting 

### the PHANTOM Flying Flow Chart, PHANTOM Quick 

### Start

Manual and 

### the PHANTOM 2Vision+ User Manual.



### lf more information or documentation is needed 

### to approve 

### this exemption, please

### contact me 

### at 515.239.8676.

Thank

### youfor your consideration, 

# Crftrt

rustinR.Dodge

# h Development Coordinator Hunziker Companies