# Transp o sur e ®

Creativ e

Mail | P.O. Box 161 . Milford . New Jersey . 08848

Studio | 643 East Broad Street . Bethlehem . Pennsylvania . 18018 PETITION FOR RELIEF OF REQUIREMENT S OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS, SPECIFICALLY AS AUTHORIZED UNDER THE F.A.A. MODERNIZATION AND REFORM ACT OF 2012, SECTION 333; SPECIAL RULES FOR CERTAIN UNMANNED AIRCRAFT SYSTEMS.

Kenneth P. Volpe , DBA as Transposure

, LLC

Transposure, LLC seeks exemptions from Title 14 of the Code of Federal Regulations: 61.113 (a) and (b); 91.7(a); 91.119; 91.121; 91. 151(a); 91.405(a); 91.407 (a) (1); 91.409(a)(1) and (2); 91.417(a) and (b), in order to operate a DJI Inspire 1 UAS

. This exemption will allow Transposure, LLC to operate an unmanned aerial vehicle commercially for the purposes of conducting aerial video and still photography in th e R eal Estate, Insurance, Engineering, Construction and Filmmaking markets of New Jersey and Pennsylvania . These still images and videos will provide both commercial and community awareness and understan ding of aerial imaging systems.

Transposure, LLC is a pr ofessional photography and videography imagery company producing high quality
results for clients who require ground and aerial based imagery for Real Estate, Insurance, Engineering,
Construction and Filmmaking purposes throughout the New Jersey and Pennsylvani a markets. Mr. Kenneth P. Volpe is the owner of Transposure, LLC. He is also the owner of a separate structural engineering company. Mr. Volpe is a licensed professional engineer in New Jersey and Pennsylvania as well as other

states. Transp osure, LLC will be using a factory spec DJI Inspire 1 quad copter to commercially capture still and video imagery while working on private and public properties for the purpo se of aerial imagery services. Transposure, LLC will employ both a pilot and visu al observer at all times to maintain a visual line

- of

- sight between the quad cop ter and the pilot UAV operator . Additional safeguards will entail the posting of ground

- based caution signs and property owner consent

.

THE DJI INSPIRE 1

The DJI Inspire 1 is an electric powered quad copter weighing less than seven pounds and is operated via a
handheld remote that features a “Return to Home” command. The Return to Home feature can be triggered manually and the UAV unit works off of a 2.4 GHz downlink for remote control. The video function

works on a 5.8 GHz frequency. The camera system is comprised of a gimbal mounted 4K image sensor and is operated from the handheld remote control. Each of the units (UAV and handheld remote) are powered by separate batteries affording the DJI Inspire 1 approximately 18 minutes of flight time. The remote control provides real time battery reserve data with both visual and audible alarms when battery power is approaching the point required for a safe “return to home” flight.

BA SIS FOR PETITION

Transposure

, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. SS 11.61) and the F.A.A. Modernization and Reformed Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petition s the Administrator to operate the DJI INSPIRE 1 UAS within the National Airspace System, and for an exemption from the requirements of 14 CFR SS 61.113(a) and (b), 91.7(a), 91.119, 91.121, 91.151(a), 91.405(a), 91.407(a) (1), 91.409(a)(1) and (2), 91.417(a ) and (b).

NAME AND ADDRESS OF THE PETITIONER

Kenneth P. Volpe , Owner Transposure, LLC
PO Box 161 Milford, New Jersey 08848 ken@transposure.com

# Transp o sur e

Creativ e

Mail | P.O. Box 161 . Milford . New Jersey . 08848

Studio | 643 East Broad Street . Bethlehem . Pennsylvania . 18018 TRANSPOSURE, LLC REQUESTS RELIEF FROM THE FOLLOWING SECTIONS OF 1 4 C.F.R.

Sections 61.113, entitled Private pilot privileges and limitations: Pilot in Command, Subsections (a) and (b).

Extent of relief from 61.113 sought by Transposure, LLC :

1. (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

2. (b) A private pil ot may, for compensation or hire, act as PIC 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 carry passengers or property for compensation or hire.

Relief from section 61.113 (a) and (b) is requested to allow a PIC to operate the DJI Inspire 1

. The flight would be complemented by a visual observer who will, along with the pilot, maintain visual line of sight with the DJI Inspire 1 at all times. All operations will be conducted as per Transposure LLC’s business related operations.

The DJI Inspire 1 is not able to carry passengers.

Section 91.7, entitled Civil airworthiness subsection (a).

Transposure LLC requests to be allowed to determine the air worthiness of the DJI Inspire 1

.
Section 91.119 entitled Minimum Safe Altitudes, General

. Relief from 91.119 is requested to allow operations of the DJI Inspire 1 at altitudes not exceed ing 400 feet AGL, over private property and/ or at a distance at o r greater than five nautical miles from the nearest airport as depicted on current aeronautical charts.

Transposure, LLC also wishes to be granted exemptions to operate at an altitude not more than 50 feet AGL
or below tree level between one and five nauti cal miles from the nearest airport as depicted on current
aeronautical charts.

Section 91.121, entitled Altimeter Settings

.
Extent of relief that Transposure, LLC seeks from 91.121(a):

Altimeter Settings

Extent of relief from 91.121 is requested because the DJI Inspire 1 utilizes an Electroni c GPS with a barometric

sensor.

Section 91.151 entitled Fuel requirements for flight in VFR conditions

.
Extent of relief that Transposure, LLC seeks in regard to section 91.151(a), Fuel Requirements for Flight in VFR
Conditions :

Relief from 91.151(b), is requested to the extent that allows Transposure, LLC to operate the DJI Inspire 1 up to a point that there is enough power to fly at normal cruising speed to the landing point and land the vehicle with 25% battery powe r remaining. ( Note: A visual low battery indicator on the operating console for

the DJI Inspire 1 is supplemented by an audible spoken alarm warning the pi lot of a low battery condition.)

# Transp o sur e

Creativ e

Mail | P.O. Box 161 . Milford . New Jersey . 08848

Studio | 643 East Broad Street . Bethlehem . Pennsylvania . 18018 Section 91.405, entitled Maintenance required

. Section 91.407 (a) (1), entitled Operation after maintenance, preventative maintenance, rebuilding, or
alteration.

Section 91.409 entitled Inspections

.
Section 91 .417 entitled Maintenance Records

.
Extent of relief that Transposure, LLC seeks in regards t o secti ons 91.405(a), 91.407(a)(1), 91 .409(a)(1) and (a)(2), 91.417(a) and (b ):

These are all associated with an airworthiness certificate. There are currently no airworthiness certificates for
small UAVs.

BENEFITS GAINED VIA RELIEF FOR TRANSPOSURE, LLC from the above stated Federal Regulations:

A. Use of the small UAV will allow for more accurate and timely aerial imagery, mapping, and surveying o f contracted imagery tasks.

B. Use of the small UAV will allow for a more economical solution for contracted imagery tasks since the cost to operate a small UAV is a fraction of the cost of operating a full size aircraft for aerial imagery

.
C. Use of the small UAV will reduce the risk to life and property as compared to the manned aerial imagery

alterna tive.

REASONS WHY SAFETY WILL NOT BE AFFECTED BY GRANTING THESE REQUESTED EXEMPTIONS:

A. Standard operating procedures prior to launch will include a comprehensive preflight checklist of the
vehicle and a ground level visual inspection of area to be surveyed

.

B. Flight operat ions will be conducted by a two

- man crew consisting of the PIC and the Visual Observer. All operations will be conducted with a clear visual line of sight (VLOS) between the team and the UAV at
all times

.
C. Transposure, LLC will only operate the UAV over private or public property with the consent of the property owner or the governing body and will maintain a safe distance from any structures, people or
vehicles.

This petition is being made pursuant to the FAA Modernization and Reform Act of 2012, Secti on 333, which directs the Secretary of Transportation to determine if any UAS may safely operate in the National Airspace.

Transposure, LLC will operate all aircraft granted for use by the exemption as directed by the DJI Inspire 1 operating manual provided by the manufacturer.

IN CONCLUSION

As set forth previously Transposure, LLC seeks an exemption pursuant to 14 CFR: 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation of the DJ I Inspire 1 UAS commercially for the purposes stated herein . The Administrator will be assisting small business by granting this petition.

Respectfully submitted by Transposure LLC.

Kenneth P. Volpe , P.E.
PO Box 161 Milford, New Jersey 08848 ken@transposure.com