September 29th, 2015

Theresa Searer 1331 Bradley Ave. Hummelstown, PA 17036 (717) 566-7408
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments:

References: 1. FAA Exemption No 12939, Regulatory Docket No. FAA2015-2297 in the matter of the petition STEVEN DOHERTY 1. FAA Exemption No. 11138, Regulatory Docket No. FAA2014-0481 in the matter of the petition of DOUGLAS TRUDEAU 2. FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3. FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, the petitioner, requests exemption from the following sections of Title 14, Code of Federal Regulations:

61.113(a), 61.113(b), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409 (a)(1), 91.409(a)(2), and 91.417(a) & (b).
In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, videography, inspections of: construction sites, solar panels, structures, roofs, real estate photography, and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the US National Airspace System as compared to a manned aircraft. Operations will be performed to facilitate commerce and raise awareness of beneficial uses of small UAS. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by section 333. The conditions identified and proposed by the petitioner is drawn from references 1-3.The FARs

The petitioner requests exemption from the above mentioned FARs for the following

reasons.
61.113(a) &(b). The petitioner, requests relief in order to facilitate the utilization of pilots, who hold a pilot (or greater) certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions. A Visual Observer will be used at all times while under this requested exemption.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms "congested areas" and "densely populated". The petitioner requests waiver for this condition to allow reasonable and responsible operations with safety as my main concern in areas of subdivisions and neighborhoods if required.
91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable.

91.405(a). 91.407(a)(1). 91.409 (a)(1) &(2). 91.417(a) &(b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would not be adversely affected.

The UAS
The DJI Phantom 3 Professional is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 45 ounces (1280g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (16m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors with a distance between motors ofless than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with

integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has fail safe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 10 minutes. More information is available in attachment 1.

Risk mitigation
The petitioner has reviewed FAA exemptions reference's 1-3 Conditions and Limitations section and believe that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UAS's airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components.

The petitioner requests that in a manner similar to reference 4, be allowed to operate within 5 miles of an airport provided that:

"The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non towered airport as denoted on a current FAA published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement with the airport management must be made available to the Administrator upon request. "
Operations within 5 miles of an airport are not anticipated to be routine but I am requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise . Operations within class B airspace are not requested due to the lack of mode C transponder.

Public interest
Use of the UAS in lieu of a manned aircraft would enhance safety and reduce environmental impact compared to similar operations conducted with much larger fuel laden manned aircraft. In addition, the use of UAS to facilitate commerce can help to encourage economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing toolthat can facilitate increased commerce and enhance personal photography. Aerial

surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risk. The petitioner will provide clients with the photographic data for these purposes in a for hire basis acting as an independent contractor. A visual observer will be utilized. Flight data including UA flight time, Control unit operation time, incident, accident, and details concerning any deviations from normal operations will be available to the FAA for use in collecting data regarding the use of UAS as a part of this application. This data can be submitted to the FAA via reports as required by the FAA.
Flight data including UAS flight time, Control Unit operation time, incident, and details will be recorded for each flight and made available to the FAA at any time needed. Any deviations from normal operations will also be recorded and made available to FAA.

Conclusion The petitioner is requesting this exemption for the purposes of aerial photography, cinematography, videography, mapping, real estate photography, inspections and other flight operations. The reason for such a general and broad based request is that the petitioner wishes to utilize a strategy that allows maximum flexibility to utilize the UA to its fullest potential within the constraints of this request, without the long turnaround time associated with additional exemptions. The petitioner plans to offer services to individuals or companies seeking to enhance their business in a safe and lawful way.

Respectfully submitted,

Theresa Searer

Attachments: 1. Phantom 3 Professional Quick Start Guide http://download.djiinnovations.com/downloads/phantom3/en/Phantom 3 Professional guick Start Guide en odf

2. Phantom 3 Professional User Manual http://download.dji-innovations.com/downloads/phantom 3/en/Phantom 3 Professional User Manual v1.0 en.ndf