15 January 2016
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590
RE: Petition for Exemption Under 14 CFR § 11.81 to Allow Commercial Use of Unmanned Aircraft Systems

Petitioner: AirBorn Imaging Tom Replogle, Owner 8000 Research Forest Dr., Suite 115-172 The Woodlands, TX 77382 Tel: 832-303-3686 Email: info@airbornimaging.com Website:www.airbornimaging.com

Dear Sir or Madam,
AirBorn Imaging has been providing high quality aerial photography and videography for over 12 years using conventional airplanes and helicopters as our aerial platforms. We are excited at the prospect of using unmanned aircraft to assist in capturing imagery for our clients. We are seeking an exemption to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes.

A. We seek exemption from the following sections: 1. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333 2. 14 CFR Part 21, subpart H 3. 14 CFR Part 61.113(a) and (b) 4. 14 CFR Part 91:
a. 91.103 (b)(2) b. 91.105
c. 91.109 d. 91.119
e. 91.121 f. 91.151 g. 91.405 h. 91.407 i. 91.409 j. 91.417

B. Relief sought: 1. AirBorn Imaging wishes to operate sUAS for commercial purposes to include (but not limited to) aerial photography, videography, photogrammetry, inspections, and analysis.2. This exemption will cover use of sUAS airframes which will weigh less than 55 pounds including payload and energy sources. Our current models include:
a. DJI Phantom 3 b. DJI Phantom 2+

3. AirBorn Imaging has been supplying the Houston realtors, construction companies and businesses with high quality aerial photographs for over 12 years. The addition of sUAS camera platforms will allow us to provide the same high quality services at a much more affordable price. In turn, the reduction of capture costs will reduce the overall cost of both private and public projects and will ultimately save the public money. In addition, when performing a risk analysis between operation of a sUAS versus conventional aerial platforms, such as airplanes and helicopters, the risk to the general public is much lower operating a sUAS.

C. Aircraft & Equivalent Level of Safety: 1. Each sUAS will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C. 2. AirBorn Imaging will comply with maintenance and inspection requirements of the manufacturer of the sUAS. All repair and maintenance work, when required, will be conducted by approved and qualified personnel. A flight test will be conducted in a safe manner after any maintenance or repair is performed. Records of maintenance and repair will be kept in maintenance log for each sUAS. 3. The PIC will be a certificated pilot holding at least a sport pilot certificate, have a current medical or driver’s license, and meet the flight review requirements of 14 CFR § 61.56. 4. A thorough preflight inspection will be performed before each mission. 5. Operations of the sUAS will be in line of sight of the PIC and/or observer and will operate in a manner to not create a hazard to users of the national airspace system or the public. 6. The PIC and observer will remain in verbal communication the entire time the sUAS is airborne. 7. The sUAS will weigh less than 55 lbs. and be operated at speeds less than 50 mph. 8. Flights will be operated at an altitude of no more than 400 ft. AGL. 9. Preflight briefings and post flight briefings will be performed for each aerial mission. 10. Flights will be performed in Day VMC conditions only and will abide by VFR cloud clearance requirements. 11. Written and/or verbal permission and permits will be obtained as necessary by local governmental agencies.12. Flights will not occur closer than 5nm of a towered or uncontrolled airport unless coordination and approval with the tower/airport manager has been received.
Thank you for your consideration for our exemption request. Please feel free to contact me if you have any additional questions.
Sincerely,

Tom Replogle AirBorn Imaging Owner