May

18, 2015 U. S. Department of Tr ansportation Docket Management Sy stem 1200 New Jersey

Av e. Wa shington, DC 20590 RE: Exemption Request Section 333 of the F AA Reform Act and Part 1 1 of the Federal Av iation Regulations
Dear Sir or Madam:
Pursuant to the Section 333 of the F AA Modernization and Reform Act of 2 012 (the "Reform Act"), Rod Coll on behalf of Eagle Ey e Aeronautical Imaging LLC (the "applicant"), the operator of Unmanned Aircraft Sy stems ("UAS") seeks an exemption from the Federal Av ia tion Regulations ("F

ARs") to allow for commercial operation for aerial imaging and video of Real Estate for Marketing and inspections of vertically developed structures such as Wi nd T urbines, Cell T owers, Power lines and Aerial Imagery of Agricultural land s to aid rural farmers with crop analy sis. Applicant: Eagle Ey e Aeronautical Imaging LLC, Rod Coll Attachments: Petition for exemption/rule making Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CF R 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.1 19 (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)Extent of relief I seek, and reasons wh y:

14 CFR Part 21 subpart H The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, I request exception. In the restricted environment and under the conditions proposed operation will be at least as safe, or safer , than a conventional aircraft operating with an airworthiness certificate without said restrictions. 14 CFR 91.7 (a)
As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no F AA regulatory

standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check list prior to each flight an equivalent level of safety will be provided. 14 CFR 91.9 (b) (2) Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity , or pilot on board to adequately carry flight manual. A e quivalent level of safety

will be maintained by

keeping the flight manual at ground control point where the pilot will have immediate access to it.
14 CFR 91.103
As F AA approved flight manuals will not be provided for the aircraft an exemption will be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances, along will all of those found in attachment "DJI Pilot Tr aining". An equivalent level of safety will be provided by

established pre

- flight protocols to properly match the machine.
14 CFR 91.109 UAS and remotely

piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by

the speed and size of the aircraft.14 CFR 91.1 13 (a) and (b)

I can achieve an equivalent level of safety as a chieved by

current regulations because my UAS does not carry

pilot nor passenger . While helpful, a pilots' license will not ensure remote control piloting skills.
14 CFR 91.121 The UAS may

not have a barometric altimeter, but instead does have a GPS alt itude read out. I believe an exemption may be needed. An equivalent level of safety is achieved by

the operator receiving live flight data monitoring and confirming current altitude along with altitude of launch site shown on the GPS altitude indicator

. 14 CFR 91.203 (a) and (b) Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate and registration documents on the aircraft. There is no room, capacity , or pilot on board to adequately

such document s. An equivalent level of safety will be achieved by keeping these documents, to the extent they are applicable to the UAS, at the ground control point where pilot has 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 section only

apply to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform pre

- flight inspections and ensure UAS is in workin g condition before initiating each flight. Rod Coll is seeking relief from all F ARs above preventing applicant from conducting aerial imaging at levels less than 400ft and at speeds well under 100mph, and with a maximum flight time of 25 minutes,. The UA S ’ to be used are DJI Phantom 2 Plus , Phantom 3, 3DR Solo and other models which are all below 5lbs pounds weight to include imaging equipment. These UAS' meet the definition of "small unmanned aircraft" found in section 331 "The Reform Act". In order to o btain high quality photography

and video the UAS will be used at speeds much less than it's top speed of 55 MPH. Due to the UAS being battery powered there are no combustible fuels on board. Maximum flight time for these particular UAS is a 25 minutes batt ery life and flights will be terminated within 25% of battery life remaining. Given the size, weight, speed, and limited operating area associated wi th the aircraft to be utilized I find this exception to be reasonable with an equivalent, or greater, level of safety to be reached by

the operator

. Safety : 1) I do not operate within 5 miles of an airport unless prior contact to Air Tr affic Control or the airport manager has been made and authorized.2) I land my

UAS prior to manufacturer recommended mini mum level of battery power 3) I pilot my

UAS through remote control by line of sight 4) My UAS uses GPS and a flight safety feature whereby

it returns to a pre

- programmed position and then slowly

lands if communication with the remote control pilot is lo st. 5) I actively

analy ze flight data and other sources of information to constantly update and enhance safety protocols. 6) I conduct extensive pre

- flight inspections during which safety carries primary

importance. 7) I alway s obtain all necessary permi ssions prior to operation. 8) I have procedures in place to abort flights in the event of safety breaches or potential danger and or inclement weather

. Public Interest The use of a UAS in the real estate industry provides both buy ers and sellers a high er level of service. For a buy er a higher level of marketing and advertising is achieved, appealing to more buy ers, resulting in a quicker sale of their home. Quicker home sales also helps accelerate the economy as a whole. Buy ers experience the benefit of encompassing a whole property , sometimes several acres, in one photo or a short video. Not only does this benefit the specific home seller or home buy er , but it benefits the general public because it is much more efficient than traditional way s of using a plane or helicopter to achieve the same result. W e can now provide this level of service while being conservative with fuel, time, emissions, noise, and other resources. Considering size, weight, speed, and absence of combustible fuels, my UAS will poses much less of a safety concern for the general public when compared to larger manned aircraft. Thank y ou for y our consideration,
Rod Coll