### Overshot Photography Attn: Jordan Meyer 905 OAve La Grande, OR 97850 541-786-9844

Dept. ofTransportation Docket Operations West Building Ground Floor Room w12140 1200 New Jersey Avenue, SE Washington, DC 20590 RE: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam, Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, Overshot Photography (SP) seeks an exemption from Federal Aviation Regulations ("FARs") detailed below for the following described Unmanned Aerial System called inthis application the DJI Phantom 2 Vision+, which includes an Unmanned Aircraft System (UAS) and ground stationbased equipment and crew THE UNMANNED AIRCRAFT SYSTEM (UAS): • A lightweight (2.7lb gross weight with all onboard equipment), battery operated 4motor rotorcraft: that takes offand lands vertically, manufactured by DJI, Model Phantom Vision Plus 2, to carry the following equipment in flight; 

### • An onboard flight computer with GPS navigation and location ability thatreceives signals for flight controls from a groundbasedtransmitter/controller; 

### • An onboard camera capable ofcapturing imagery inthe form offull color, high definition still photos and video; 

### • An onboardtelemetry system that delivers flight data from the onboard flight computerto the onboard radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction backto its launch site; • A 600mW, 5.8GHz onboard radio transmitter that transmits live video from the onboard cameraplus all the flight data from the telemetry system described above; THE GROUND STATIONBASED PART OF THE SYSTEM: • A Pilot in Command (PIC) in operational control ofa flight operation from beginning to end and who controls the UA while inthe air; • A 100mW, 2.4GHz radio transmitter/controller operated bythe PIC to control the UA while in flight; • A radio receiver receiving live video and flight data from the onboard camera and computer projects it all together onto a screen for the PIC to view during flight; • A Visual Observer (VO) who provides a second pair ofeyes to visually trackthe UA while in flight. The requested exemption would support an application for a commercial Certificate ofAuthorizationto use the above described UAS to support aerial photography and video primarily ofreal property,specifically individual properties ofat leasttwo acres in size (equivalentto a square 295 feet/side). The UAS, poweredbybatteries, is smaller, lighter and more maneuverablethan larger aircraft running on combustible fuel, it operates at lower altitudes with no people onboard and will thereby reduce current risk levels andthereby enhance safety and diminish the likelihood ofdeath or serious bodily injury. With a small payload and maximum flight time ofonly 20 minutes, this is offers little or no riskto national security. Low level oblique photos and video from several angles are far more effective than groundbased imagery for displaying the characteristics oflarge, complexproperties with several buildings and large trees. Helicopters canbe used, butthey are more expensive to and not able to fly as low. The benefits of reduced cost and improved quality ofpresentation from the UA will be valuable to andbenefit many buyers and sellers ofreal property. Additionally, we requestthat we be allowedto use our systemto benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, FEMA, et al., while remaining subjectto all limitations cited inthis application as we do so. The UAS will be operated inthe field with both a PIC and aVO in accordance with FAA PolicyN 8900.227 Section 14 "Operational Requirements for UAS" and withthe following Restrictions: (a) No flight will be made with a UA Gross weight exceeding 55 pounds; (b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed ofno more than 25 knots and no further than 3/4 NM from the PIC; ' (c) All operations must utilize a visual observer (VO). The VO and PIC mustbe able to communicateby voice at all times during a flight operation; (d) Operations will be restricted to flights over private property withthe permission ofthe property owner; (e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 

### (b), a minimum of 100 flight cycles and 25 hours oftotal time as a UA rotorcraftpilot and at leastten hours logged as a UApilot with a similar UAtype; (f) All required permits will be obtained from state and local government priorto operation; (g) The UAS will notbe operated over densely populated areas; (h) The UAS will not be operated at air shows; (i) The UAS will notbe operated over any open air assembly ofpeople; 

### (j) The UAS will notbe operated over heavilytrafficked roads; (k) The UAS will notbe operated within 5 NM ofan airport orheliport; (1) The UAS will notbe operated over properties smallerthantwo acres in size; (m) Operations will be restricted to day only and weather conditions equivalentto VFR; (n) The PIC will briefthe VO andproperty owner aboutthe operation and risk before the first flight at each new location; (o) No flight maybe made without a preflight Inspection bythe PIC before each operationto ascertain that the UA is in a condition safe for flight (see Appendix A). The PIC and VO will meetthe requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance onthe system and \vill complete a course ofmaintenance instruction as part oftheir initial training. We submitthatthe combination ofthe UA's lightweight, flight performance and ability, fully qualified flight crew and strict operationunder the guidelines established in 8900.227, and under all ofthe Restrictions (a) through (o) listed above, the FAA canhave full confidence thatthe operation will have an equivalent or greater level ofsafetythan manned aircraft performingthe same mission.

### The name and contact information ofthe applicant is. Overshot Photography Attn: Jordan Meyer Phone: 541-786-9844 Email: Jordan.Mever@overshotphoto.com The regulations from whichthe exemption is requested are listed below. Beside each regulation number is the page ofthe attached Addendum upon which each may be found together with our proposed equivalent level ofsafety for each regulation: • 14 CFRPart 21..

...............................Addendum Page 1 • 14 CFR 91.203

.................................Addendum Page 1 • 14 CFR45.23, 45.29

..........................Addendum Page 2 • 14 CFR91.9

....................................Addendum Page 2 • 14 CFR 61.113, 61.133

.......................Addendum Page 3 • 14 CFR 91.109, 91.119, 91.121..

............Addendum Page 3-4 • 14 CFR91.151..

...............................Addendum Page 4 • 14 CFRSubpartE (91.401 91.417)

......Addendum Page 4 • FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

...Addendum Page 5 We are preparedto modify or amend any part ofthis request to satisfy the need for an equivalent level of safety. Please contact us at anytime ifyou require additional information or clarification. We look forward to working with your office. Sincerely, 

# ou-r

Jordan Meyer Owner

- Overshot Photography

The Following are included. Addendum containing Exemption Requests and Equivalent Level ofSafety Appendix A - Preflight Inspection & 

### Emergency Procedures Appendix B - Owner's Manual for UAS/•



# Addendum

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY



### Overshot Photography requests an exemption from the following regulations as well as any additional regulations thatmay technically apply tothe operation ofthe UAS:

14 CFR Part 21, Subpart H: Airworthiness Certificates 

### This part establishes the procedures for the issuance ofan airworthiness certificate. While the FAA continues to workto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the UAS under either orboth ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development.Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations.Conducting flight tests and other operations to show compliance withthe airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance withthe function and reliability requirements ofthe regulations. Since the experimental certificate canbe used for commercial purposes such as market surveys, sales demonstrations, and customer crewtraining, we would expectthat an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily ofcarbon fiber and plastic, we propose that the UA will be at least as safe, ifnot safer, than a conventionally certificated aircraftperforming the same mission. Ifan experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFRPart 21, Subpart H, 

### andthe requirement for an airworthiness certificate in general, citing the equivalent level ofsafety outlined inthe previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

### The regulation provides that an airworthiness certificate, withthe registration number assigned to the aircraft and a registration certificate mustbe aboardthe aircraft. Additionally, subparagraph (b) provides

### thatthe airworthiness certificate be "displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of2.7 pounds, the UA is too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers or crew. To obtain an equivalent level ofsafety and meet the intent of91.203, we propose that documents deemed appropriate for tllis aircraftbythe FAA will be in possession ofthe crew atthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose that the information found on airworthiness andregistration certificates bepermanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL"to satisfythe requirement of 14 CFR45.23, which follows immediately afterthe proposed placard description below: EXPERIMENTAL Manufacturer: DJI Innovations, Inc. 55 South A Street Suite 110 Pensacola, FL 32502 Model: Phantom Vision 2 Plus Iffound please contact: (541)786-9844



### 14 CFR45.23 Display ofmarks; general and 45.29 Size ofmarks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters atleast 3 inches high. Additionally, the aircraftmust display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The UA does not have an entrance in which the word "EXPERIMENTAL" can beplaced, and may not have a registration number assigned to itbythe FAA. We proposeto achieve an equivalent level ofsafety by includingthe word "EXPERIMENTAL" in the placard onthe top ofthe aircraft, as shown above, where the PIC, VO and others inthe vicinity ofthe aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel thatthe permanent placard discussed in the previous paragraph will provide the aircraft's registration information atthe ground station. Finally, we wi.ll display atthe ground station a high contrast flag or bannerthat contains the words "Unmanned Aircraft Ground Station" inletters 3 inches high or greater. Since the aircraft wi.ll operate within 3/4 NM ofthe ground station, the banner shouldbe visible to anyone that observes the aircraft and chooses to investigate its point oforigin.



### 14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is inthe aircraft. We assume thatthe intent ofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemptiontothis requirement since the aircraft is not onlytoo small to carry documentation, the documentation would notbe available to the crew during flight operations. To obtain an equivalent level ofsafety and meet the intent of91.9, we propose that a current, approved UA FlightManual (Appendix A) must be available tothe crew atthe ground station anytime the aircraft is in, 

### or preparing for, flight.14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no personthatholds a private pilot certificate may act as pilot in command of an aircraft for compensation orhire. Subparagraph (b) allows a private pilotto act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carrypassengers orproperty for compensation or hire. Ourproposed operations require thatthe PIC must either 1. Hold a Commercial Pilot Certificate issued bythe FAA, and have logged 25 hours offlight experience inthis type ofUA, or 2. Meetthe requirements of8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in whichthe PIC is required to complete "FAAprivate pilot ground instruction" and pass "the FAA Private Pilot ·written examination." Since there are currently no means available for the pilot ofa UAS to gainthe experience in an equivalent category and class in orderto apply for a commercial pilot's license, we propose to generate an equivalent level ofsafety by requiring our pilots to complete a minimum of 100 logged hours ofUAS flight time. Since the aircraft cannot carry passengers orproperty, we feel we meetthe intent of61.113 Subparagraph (b) eventhoughthe intent ofthis application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate a civil aircraftthat is being used for flight instruction unless that aircraft has fully functioning dual controls." The UAS ground-based control station consists of a small handheld radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set ofcontrols simultaneously. Withboth student and instructor having "hands-on" the controls during flight, we feel thatthis technique meets the intent 91.109 and provides an equivalent level ofsafety. 14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closerthan 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of400 feet AGL, we cannot comply with this requirement. 

### In order to provide an equivalent level ofsafety we will only fly over private property with a size ofat leasttwo acres withthe permission ofthe owner ofthe property flown over. The aircraft will not be operated over congested areas or over any open air assembly ofpersons. The property owner will be briefed onthe expected route offlight andthe associated risks to persons and property onthe ground. The aircraft will be operated at a low altitude allowing, ifa powerunit fails, an emergency landing \vithout undue hazardto persons orproperty onthe surface. Therefore we maintainthat due to the small size ofthe UA, the hazard to persons, vehicles and structures is minimal comparedto manned aircraft, which should be considered in granting the exemption.



### 14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement abovethe takeoffpoint is transmitted via radio from the UA onboard computerto the display screen held bythe PIC, providing a constantly updated AGL readout.



### 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day VFR conditions unless there is enough fuel to fly to the first point ofintended landing andto fly after that for at least 30 minutes. We feel the intention oftl1is paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UAS is battery operated andthe maximum duration offlight from a single battery charge is 18 minutes with a 20% reserve. Since the aircraft will never fly more than % NM from the point of intended landing, a full battery charge at launch will ensurethat we meetthe reserve energy requirement ofthis paragraph. We request an exemptionto the word "fuel" and ask for an equivalent interpretation with the word "energy".



### 14 CFR Subpart E (91.401 91.417) Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that tl1e aircraftbe "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intentionthatthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for returnto service." As provided inthe PreFlight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy condition priorto every flight and in addition conduct detailed inspections after everytwo hours offlight. Maintenance performedbythe PIC is limitedto repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for tl1e onboard computer. All other maintenance will be performedbythe manufacturer ortheir designated repair facility. The PIC will document workperformed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety.

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### FAA 8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(l) Observer Medical. This policy provides thatboththe PIC and VO musthave a valid FAA secondclass medical certificate issued under part 67 in order to perform as a pilot or observer. The UA maximum gross weight is 2.7 pounds, it is constructed ofcarbon fiber andplastic and the PIC is not onboard. Boththe PIC andthe VO are required to be in VLOS. Given the unlikely event thatboththe PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site oflaunching and landwithout crew intervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden. We propose thatthe minimum medical requirements for the PIC and VO be vision correctedto 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure thatthe PIC and VO can see and avoid airtraffic; a licensed driver is medically qualifiedto operate a much larger vehicle. 

### APPENDIX A- FLIGHT MANUAL FLIGHT RESTRICTIONS (a) No flight will be made with a UA Gross weight exceeding 55 pounds; (b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at an airspeed ofno more than 25 knots and no further than 3/4 NM from the PIC; (c) All operations must utilize a visual observer (VO). The VO and PIC must be ableto communicate verbally at all times during a flight operation; (d) Operations will be restricted to flights over private property withthe permission ofthe property owner; (e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 ( 1

), a minimum of 100 flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UAtype; (f) All required permits will be obtained from state and local government priorto operation; (g) The UAS will notbe operated over densely populated areas; (h) The UAS will notbe operated at air shows; (i) The UAS will notbe operated over any open airassembly ofpeople; (j) The UAS will not be operated over heavilytrafficked roads; (k) The UAS will notbe operated within 5 NM ofan airport orheliport; (I) The UAS will not be operated overproperties smallerthantwo acres in size; (m) Operations will be restrictedto day only and weather conditions equivalentto VFR;

### (n) The PIC will briefthe VO and property owner aboutthe operation and risk before the first flight at each new location; (o) No flight may be made without a successful PreFlight Inspection bythe PIC before each operationto ascertainthatthe 

### VA is in a condition safe for flight. PREFLIGHT CHECKLIST

(1) 

### Use voltmeterto determine that UA battery is fully charged in order to prevent unexpectedpremature descent; (2) Check all wiring connections are tight; (3) Check all propellers are undamaged and no cracks exist in 

### any structural members ofthe 

### VA;
(4) Turn on radio controller, check for adequate voltage, set itto com1ect tothe 

### VA, move all control switches to forward or dmwposition and throttle control stick full backposition; (5) Connect 

### VA main battery, check for radio contact with UA's radio receiver; (6) At a location different from previous flight, reset GPS and compass to current location; (7) Tum on transmitter, gimbal and camera.

TO REGAIN CONTROL AFTERLOST RADIO CONTACT 1. 

### Failsafe= ON 2. Throttle= 50% 3. Mode=ATTI 4. Failsafe= OFF 5. Mode=GPS Ifradio contact is not restored, the 

### VA will automatically continue at 60 

### ft above its last elevation before losing contacttoward its takeoffpoint, then descend and landthere autonomously