Revette Studio, Inc.

STUDIO

6167 Eastern Ave.

Syracuse, NY 13211

PHONE

315-463-4499

CELL

315-436-9243

FAX

315-463-8015

EMAIL

dave@revette.com

WEB

www.revette.com

March 9, 2016

US Department of Transportation

Docket Management System

1200 New Jersey Ave

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations

To Whom it May Concern,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the

"Reform Act") and 14 C.F.R. Part II, Revette Studio, Inc. seeks exemption from

the Federal Aviation Regulations below to allow for commercial operation of an

unmanned aircraft system for the purposes of architecture, construction, real

estate photography and more. Revette Studio is an architecture and real estate

photography studio, established in 1984, that seeks to operate legally, offering

aerial photography, among other services, to architects, builders, property

owners, real estate agents and other organizations and institutions.

Extent of Relief

14 CFR Part 21 subpart H

I request exemption based on the size, weight, speed, and limited operating area

associated with the aircraft. It carries neither pilot nor passenger and no

explosive materials or flammable liquids. In the restricted environment and

under the conditions proposed, operation will be as safe, or safer, than a

conventional aircraft.

14 CFR 91.7 (a)

No FAA regulatory standard currently exists for determining airworthiness of

this aircraft. Nor is there an appropriate airworthiness certificate. With

exemption, the pilot in command will be responsible for determining whether

the aircraft is in condition for safe flight.
14 CFR 91.9 (b) (2)

Given its size, the aircraft does not have the ability to carry a flight manual, nor

does it carry any pilot or passenger to reference one. An equivalent level of

safety will be maintained by keeping the flight manual at ground control where

the pilot in command will have immediate access to it.

14 CFR 91.103

Exemption is requested because FAA-approved flight manuals are not available

for the aircraft. Standard pre-flight procedures will include: aircraft inspection,

review of weather forecasts, assessment of aircraft battery level, inspection of

takeoff/landing locations and more.

14 CFR 91.105

Exemption requested: does not apply because the aircraft does not carry crew

members.

14 CFR 91.109

Exemption is requested because the UAS does not have fully functional dual

controls. Flight control is achieved through the use of a remote controller that

communicates with the aircraft via radio communication. The equivalent level

of safety is ensured because the aircraft carries neither pilot nor passengers.

14 CFR 91.119 (c)

Exemption is requested because the aircraft will not fly above 400 feet and will

not fly over highly populated areas.

14 CFR 91.121

The aircraft uses electronic GPS with a barometric sensor for altitude readings.

Exemption is requested because it does not have an altimeter.

14 CFR 91.151

Exemption requested: does not apply because the aircraft does not run on fuel.

14 CFR 91.203 (a) and (b)

Given its size, the aircraft does not have the ability to carry registration

STUDIO

6167 Eastern Ave.

Syracuse, NY 13211

PHONE

315-463-4499

CELL

315-436-9243

FAX

315-463-8015

EMAIL

dave@revette.com

WEB

www.revette.com

Revette Studio, Inc.
documents, nor does it carry any pilot or passenger to reference one. An

equivalent level of safety will be maintained by keeping these documents, to the

extent that they are applicable, at ground control where the operator will have

immediate access to them.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a)

and (b) Given these sections only apply to aircraft with an airworthiness

certificate, they not apply to this applicant. For safety, standard pre-flight

inspections/procedures will be performed before each flight.

The Unmanned Aircraft System

The Aircraft: A Phantom III Professional, manufactured by DJI. It is a battery-operated

quadcopter that weighs 2.8 lbs and has a maximum speed of 33.5 mph.

Maximum flight time for the aircraft is 25 minutes. It carries the following

equipment in flight:

● A flight computer with GPS navigation that receives flight control signals

from a ground-based transmitter/controller. The computer has the ability to send

flight data to the on-board radio transmitter including altitude, horizontal and

vertical speed, compass direction of flight and direction back to its launch site.

● A camera capable of capturing images in the form of full color, 4K definition

video and 12mp still photo images.

● A 2.483 GHz on-board radio transmitter that transmits live video from the onboard camera to the ground station, as well as flight data including altitude,

horizontal and vertical speed, compass direction of flight and direction back to

its launch site.

The Ground Station: A 2.483 GHz radio receiver/controller, operated by the

pilot in command to control the aircraft from launch to landing.

STUDIO

6167 Eastern Ave.

Syracuse, NY 13211

PHONE

315-463-4499

CELL

315-436-9243

FAX

315-463-8015

EMAIL

dave@revette.com

WEB

www.revette.com

Revette Studio, Inc.
Public Interest

The public will benefit by granting this exemption by:

● Use of the UAS will support local commerce, leading to economic

growth. Safe, efficient, affordable aerial photography allows architects,

construction firms, property owners and real estate agents greater

perspectives on private and commercial properties, thereby greatly

enhancing their marketing tools.

● Use of the UAS for aerial photography, will enhance safety and

reduce the environmental impact as compared to similar operations

conducted with manned aircraft, carrying a crew and flammable fuel.

● Aerial inspections of construction/building sites will increase work

site efficiency, reduce risk and improve workplace safety.

Safety

The DJI Phantom III Professional meets the definition of “small

unmanned aircraft”found in section 331 of The Reform Act. Standard safety

precautions may include, but are not limited to:

● regular performance of preflight safety inspections/procedures

● maintaining records of flight information (flight logs)

● The aircraft will be operate ed within visual line-of-sight at all times

● no operations within 5 miles of an airport, unless proper permission

has been obtained

STUDIO

6167 Eastern Ave.

Syracuse, NY 13211

PHONE

315-463-4499

CELL

315-436-9243

FAX

315-463-8015

EMAIL

dave@revette.com

WEB

www.revette.com

Revette Studio, Inc.
● areas to be flown/photographed are predetermined, allowing time for careful

inspection of the terrain before take-off

● all operations to take place during daylight hours

● built in GPS allows for automatic “return-to-home” in the event of low

battery or loss of

communication.

● all operations to occur in FAA Class G airspace at no more than 400ft.

Liability insurance will be obtained upon receipt of exemption.

Summary

Revette Studio, Inc. is seeking relief from the Federal Aviation Regulations

above to allow commercial operation of an unmanned aircraft system for

purposes of architecture, construction, real estate photography and more. Given

the size, weight, speed, and limited operating area associated with the aircraft I

find this exception to be safe and reasonable.

Please let me know if I can provide further information. I look forward to your decision.

Sincerely,

David Revette

Revette Studio, Inc.

STUDIO

6167 Eastern Ave.

Syracuse, NY 13211

PHONE

315-463-4499

CELL

315-436-9243

FAX

315-463-8015

EMAIL

dave@revette.com

WEB

www.revette.com

Revette Studio, Inc.