U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New JerseyAvenue, SE Washington, DC 20590

Air Imaging LLC 3778 Kay Drive Stow Ohio 44224 330-815-5329 rodeo428@yahoo.com -_) ,-¥-... =-., .,.__ -:_- ·-**~"**

Subj: Petition for Exemption to Operatethe DJI Phantom 2 sUAS forthe Purpose of Real Estate Photography.

Dear Sir or Madam, Air Imaging LLC (AI) is requesting exemption from the Federal Aviation Administration for certain Federal Aviation Regulations so that (AI) may use a sUAS in conducting the business ofproviding aerial photography in the real estate market. (AI) intends to offer aerial photography services to any concern where a sUAS can replace putting a human in dangerous situations. The sUAS that (AI) will be using is the DJI Phantom 2 Quadcopter. The DJI Phantom 2 has safetyfeatures that include Return HomeAutomatically ifthe sUAS should exceed its control range and a No Fly Zone warning feature that alerts the PIC and VO ifthe sUAS gets to close to an airport. The sUAS will return to its launch point automatically when it determinesthe battery levels are too low. The Phantom 2 has a take-offweight of 1250g and operates at 5.8 GHz. Accent/decent speed is 6m/s. Maximum flight speed is 10m/s.

RE: Requestfor Exemptions Pursuantto Section 333. Part 11,14CFR-Part21-Subpart H; Part36; 45.23; Part61.113(a)&(b); 91.7(a); 91.9; 91.103; 91.109; 91.119; 91.121; 91.151(a)-(1); 91.203; 91.405(a).

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## 114 CFR-Part 21 Subpart H -Airworthiness Certificate, Certification Procedures. 14 CFR-Part 36- Noise Regulations. 14 CFR-45.23 - Display Markings. 14 CFR-Part 61.113(a)&(b)- Certifications for Instructors and Pilots. 14 CFR-91.7- Civil AirWorthiness. 14 CFR-91.9- Flight Manuals and Marking Requirements. 14 CFR-91.103- PreflightActions. 14 CFR-91.109 - Flight Instruction. 14 CFR-91.119 - Minimum SafeAltitudes. 14 CFR-91.121 -AltimeterSettings. 14 CFR-91.151- VFR Requirements for Fuel. 14 CFR-91.203- Certificates Required for Civil Aircraft. 14 CFR-91.405(a)- Maintenance Required. 14 CFR Part21-Subpart H- (AI) asks for exemption from an Airworthiness Certificate because ofthe size, weight and speed ofthe sUAS in comparison to manned aircraft makesthe risks involved negligible in comparison.

14 CFR Part 36 - (AI) asks for exemption from noise standards dueto the sUAS size and low noise impact. 14 CFR 45.23 - (AI) asks for exemption from the marking requirements for aircraft. The size ofthe sUAS will not accommodate the minimum 2" letters. 14 CFR Part 61.113(a)&(b)- (AI) asks for exemption from the certification requirements for pilots. Whilethe sUAS will only be operated over private propertywith the consent of that property owner it is our beliefthatthe 40 plus hours ofoperating the sUAS bythe PIC and theVO with the full understanding ofthe FAA Rules and Regulations governing the use ofsUAS is sufficientto operate it safely in the NAS. 14 CFR 91.7- (AI) asks forexemption from this FAR forthe same reasons being requested for Part 21-Subpart H.



### [2]14CFR 91.9- (AI) asks for exemption from this FARforthe 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 - (AI) asks forexemption from this FAR as it pertains to manned aircraft. All appropriate pre-flight actions will be taken with the sUAS. 14CFR 91.109- (AI) asks for exemption from this FAR as the sUAS uses a single ground controller. 14 CFR 91.119- (AI) asks forexemption from Minimum Safe Altitudes overvarious areas in orderto accomplish the intended mission. 14 CFR 91.121 - (AI) asks for exemption from this FAR as the sUAS does not have an altimeterthat this FAR refers to. OursUAS has a flight ceiling of300' AGL and will be monitored bythe PIC. 14 CFR 91.151- (AI) asks for exemption from the VFR-Fiight Fuel carrying requirements as oursUAS is battery powered. 14 CFR 91.203- (AI) asks forexemption from this FAR as it requires an Airworthiness Certificate. (AI) requested relieffrom an Airworthiness Certificate in Part 21-Subpart H. 14 CFR 91.207- (AI) asks forexemption from operating oursUAS with an Emergency LocatorTransmitter. OursUAS will always be flown within VLOS rules. 14CFR 91.405- (AI) asks for exemption from this FAR as all maintenancewill be done bythe PIC and VO as recommended bythe manufacturer.

Our mission for safe operation in the NAS will be to always stay belowthe 300' ceiling, operate onlywithin VLOS bythe PIC and the VO and to end all flights when battery capacity reaches 25%. Additionally (AI) will notoperatethe sUAS in public places or above crowded areas. Before we deploythe sUAS wewill stand signs at each end of the operating area to alertthe publicthat aerial photography is taking place. Priorto each flightthe PIC and the VO will examine theflight area for overhead power lines, trees, [3]and any other obstacles that could threaten public safety. Weather conditions would be the final determining factor before each flight. Iwill be the PIC. I have over40 hours flying time with the OJI Phantom 2. The VO has over20 hours offlying time with the Phantom 2. OursUAS will be flown only during daylight hours and only underVLOS rules. (AI)'s goal is to provide a quality service while adhering to all FAA rules forsafe flight. Before and after each flight the PIC and the VO will visually inspect all rotor blades, electrical connections, battery conditions and levels and test the link between the sUAS and the controller. It is our beliefthat by using a sUAS in place ofmanned aircraft greatly increases the safety ofthe general public. OursUAS is compact, lightweight, carries noflammable fuel and has no humans on board. Coupled with the sUAS relatively slow airspeeds and that it is being operated within VLOS and under 300' AGL by a qualified PIC and VO we feel thatthe risks of using a sUAS to conduct aerial photography have been greatly reduced. Thank you foryourconsideration, Respectfully,

# f'7~ JayThierfelder President Air Imaging LLC

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