Omar Herrera (Proposed Dba: iDroneV ision) SECTION 333 EXEMPTION PETITION Page 1 of 4 Omar Herrera (Proposed dba: iDroneVision)

21 Kristi Lane Woodbury, NY 11797

June 5, 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE. Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR Part 21 subpart H, 14 CFR 45.23 (b), 14 CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119 (c) , 14 CFR 91.121, 14 CFR 91.203 (a) and (b), 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1) , 14 CFR 91.409 (a) (2 ), 14 CFR 91.417 (a) and (b)

Dear Sir or Madam,

I, Omar Herrera (proposed dba: “ 

## i DroneVision ”), write this letter pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contain ed within 14 C.F.R.11, and request that I, Omar Herrera, a Licensed Real Estate Broker for over 12 years and owner/operator of a small unma nned aircraft system (“UAS”), be exempt from the Federal Aviation Regulations (“FARs”) listed below and be granted exem ption to operate an unmanned aircraft system (“UAS”) commercially in airspace regul ated by the Federal Aviation Administration (“FAA”).

The Exemption Reque st would be for a DJI Inspire 1, Model T 600 UAS that I own, with

intent to commercially offer for compensation low cost aerial photography and videography to other real estate brokers / agents within the NAS. In the public interest this will enhance their listings offered for sale in today’s co mpetitive market without the high cost of using manned aircraft for aerial photography and v ideography. The use of UAS’s in the real estate industry provides both buyers and sell ers a higher level of service for marketing and advertising appealing to more buyers, resulti ng in fewer days on the

market sales. Home sales also increase the economy as a whole. I will be able to provide a high level of service without t he use of high cost fuel, emis sions, and loud manned aircraft noise and in less time. Considering size, weight, spee d, and the DJI Inspire 1 UAS will poses much less of a safety concern for the general pu blic when compared to larger costly manned aircraft.Omar Herrera (Proposed Dba: iDroneV ision) SECTION 333 EXEMPTION PETITION Page 2 of 4 I, Omar Herrera, am experienced in building and flying remote c ontrolled hobby helicopters for recreational pur poses for over 22 years without any accidents. I currently

have over 55 hours of remote cont rol flying including additiona l DJI Pilot training for the DJI Inspire 1 UAS. I’m also an insured member of the AMA (Academy of Model Aeronautics). Safety is my numbe r one priority, therefore pre-f light inspections and post flight inspections are always pe rformed as recommended by the m anufacturer owner’s manual and documented in a flight log.

The DJI Inspire 1 UAS has a maximum gross weight of 6 pounds 7.5 ounces, a lengt h of 17.3 inches, width of 17.7 inches, height of 11.8 inches, an d a maximum speed of approximately 42 knots. All photography and video of real estate will be taken at levels o f approx. 200ft above ground level (AGL), at a speed less than 17 knots, and with a maximum flight time of 13.5 mi nutes allowing additional remaini ng return to home position flight time. The DJI Inspire 1 UAS meets the definition of "small unmanned aircraft" found

in section 331 "The Reform Act". The DJI Inspire 1 UAS is battery powered there are no

combustible fuels are onboard. M aximum flight time for the DJI Inspire 1 UAS is approx., 18 minutes with a TB47, 4500mAh, 22.2 V LiPo 6S battery and app rox., 22 minutes TB48, 57mAh, 22.8 V LiPo 6S battery. For safe a return, all flights a re terminated with 25% battery life remaining. Given the size, weight, speed, and limi ted operating area

associated with the aircraft t o be utilized I find this excepti on to be reasonable with an equivalent, level of safety to be reached by the Pilot in Command (PIC).

I, Omar Herrera therefore, as Petitioner, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and R eform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Inspire 1 UAS in the National Airspace System (NAS), and for an exemption from the requiremen ts of Regulations from 14 CFR Part 21 subpart H,14 CF R 45.23 (b),14 CFR 91.7 (a),14 CF R 91.9 (b) (2),14 CFR 91.103, 14 CFR 91.109, 14 CF R 91.119 (c), 14 CFR 91.121, 14 CFR 91.203 (a) and (b), 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CF R 91.417 (a) and (b).

14 CFR Part 21 subpart H In consideration of the speed, w eight, size, and limited operat ing area associated with the UAS and its operation, the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, I reques t exemption of an airworthin ess certificate in

accordance with 14 C.F. R. Part 21, Subpart H.

14 CFR 45.23 (b)
The DJI Inspire 1 UAS does not have a cockpit, cabin, or pilot station on which t o market certain words or phrases due its dimensions. However, in compli ance with FAA regulations, the UAS’s fuselage will be marked with lettering a nd/or “N” numbers as large as possible to identify the aircraft as required by the FAA rul ing to preserve the equivalent level of safety and compliance.Omar Herrera (Proposed Dba: iDroneV ision) SECTION 333 EXEMPTION PETITION Page 3 of 4 14 CFR 91.7 (a)
The DJI Inspire 1 UAS do not require an airworthi ness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Acc ordingly, I, Omar Herrera will submit and ensure that the DJI Inspire 1 UAS is always in airworthy condition, prior t o every flight, by determining that the UAS is compliance with the operating documents for the DJI Inspire 1 UAS, and pre-flight and maintenance logs for the aircraft’s safe flight conditions.

14 CFR 91.9 (b) (2)
Due to the dimension and configuration the DJI Inspire 1 UAS, the UAS does not have the means of to carry a flight manual on board. I, Omar Herrera , consequently request exempt from 14 CFR 91.9 (b) (2) because the flight manuals, are maintained within my reach at all times on the ground, both in print format and elec tronic “pdf “ format with immediate access should it be necessary.

14 CFR 91.103
The DJI Inspire 1 UAS does not have an FAA approved flight manual. However, I req uest exemption 14 CFR 91.103 because procedures for weather check, G PS satellites, flight battery levels, landing and take-o ff measurements, compass cali brations and other flight telemetry are found in the DJI Pilot App and provide an equival ent level of pre-flight protocols.

14 CFR 91.109
The DJI Inspire 1 UAS does not have fully functiona l dual controls since it is re motely piloted via radio communication s from the aircraft to a hand he ld transmitter. Since the DJI Inspire 1 UAS does not carry a pilot or pa ssengers the comparable level o f safety and control is retained by t he Pilot in Command (PIC).

14 CFR 91.119 (c) In compliance with 14CFR 91.119, I, Omar Herrera as Pilot in Co mmand (PIC), fly only within visual line-of-sight (VLOS ) or the VLOS of a visual obse rver (VO) when required

. The UAS remains at least 500 feet from other people in order to not pose an unwarranted hazard to persons and property. All flights are conducted durin g daylight-only hours (sunrise to sunset). Flights ar e never conducted from a moving vehicle. No flights are

ever conducted within 5 miles of a n airport. No flights are eve r over 400 feet above ground level (AGL). No flights are ever less than 3 miles visibility f rom the home point.

14 CFR 91.121
The DJI Inspire 1 UAS does not have a typical barometric altimeter onboard. Howev er, altitude information is provided via Global Positioning System (GPS) equipment and radio communications telemetry data lin k, which is downlinked from th e DJI Inspire 1 UAS to

the PIC’s remote control screen ac tively monitoring the flight path. This altitude information, combined with other flight telemetry and flying th e DJI Inspire 1 UAS only within visual line of sight, and below 400 feet AGL, will ensur e an equivalent level of safety. In addition should comm unications be lost at any point, the DJI Inspire 1 UAS will automatically return to the home position (failsafe mode) via G PS, and will descend to the takeoff position and shutdown.Omar Herrera (Proposed Dba: iDroneV ision) SECTION 333 EXEMPTION PETITION Page 4 of 4 14 CFR 91.203 (a) and (b) Given the similarities of, 14 CFR 91.9 (b) (2) Due to the dimen sion and configuration the DJI Inspire 1 UAS, the UAS does not have the means of to carry a flight manu al on board. An equivalent level of safety is maintained within my reach at all times on the ground by having the flight manuals in pr int format and electronic “pdf” format with immediate access should it be necessary.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) , 14 CFR 91.417 (a) and (b) Furthermore, I, Omar Herrera reques t relief from Sections 91.40 5(a),91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections s et forth requirements for maintenance that only apply to air craft with an airworthiness c ertificate.

I, Omar Herrera, submit that the requested relief is appropriat e since an equivalent level of safety will be ensured by perfo rming preventive maintenance on the DJI Inspire 1 UAS using the methods, techniques, and practices prescribed in the operating documents for the DJI Inspire 1. Furthermore , I document and maintain all fli ghts and maintenance

records for the DJI Inspire 1 UAS and will made available for inspection by the FAA at any time upon request.

In consideration of the FAA gr ating me the above Section 333 Ex emption Petition, I thank

the FAA in advance for the effo rts to stablish proper regulatio ns and protocols for the use

of UAS’s within the national airs pace. I further standby to sup port and cooperate with the FAA with any request regar ding the public safety.

Thank you.

Sincerely,

Omar Herrera

Attachments : DJI Maintenance Manual, DJI Safet y Guidelines, Flight/Mainten ance Log Sheet