# Elite Aerial Images **3210 Bird Dr -**  **Erie -**  **PA 16510 814**  **- 897**  **- 9637** 

1 U.S. Department of Transportation Docket Management Sy stem March 16, 2014 1200 New Jersey

Ave. SE Washington, DC 20590 Re: **Exemption Request Section 333 of the FAA Reform Act** Dear Sir/Madam I am submitting this petition on my own, on the behalf of m y compan y Elite Aerial Images, Co. without the aid of legal council. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Elite Aerial Images, Co. (EAI) which is owned and operated by Douglas Woodcrafters, Co., a sole proprietor, operating in the State of Penns yl vania. EAI who has been building and operating Small Unmanned Aircraft Sy stems for the past 5 y ears, wishes to apply

for an exemption from the Federal Aviation Regulations ( FAR) listed below to allow operation of our sUAS commerciall y in airspace regulated b y the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established b y the FAA as r equired by Section333. The requested exemption would permit EAI to pursue its commercial interests in providing services to companies interested in aerial data that can only be captured b y using newly developed sUAS in the following areas:

 Survey ing an d 3D aerial mapping  Agriculture crop assessment and growth patterns  Golf course management  Insurance compan y claim assessment  Special events  Construction site and ecological impact assessment EAI asserts that all sUAS flights that will occur over private or controlled access propert y will do so with the propert y owner’s consent and knowledge and that onl y people who have consented or otherwise have agreed to be in the area where flight activity is taking place. Additionally , I am a private pilot with 3,0 00 hours of flight time logged and am the sole operator of the sUAS we own and operate. Our observers will attend ground school to be taught the rules and regulation as they pertain to operating private aircraft under Visual Flight Rules (VFR) over civili an population areas as described and set fourth in the Aeronautical Information Manual.

# Elite Aerial Images **3210 Bird Dr -**  **Erie -**  **PA 16510 814**  **- 897**  **- 9637** 

2 **The substance of this request is essentially the same as that granted to Falcon Sky Cam Regulatory Docket No. FAA**  **- 2014**  **- 0884**  in that EAI is engaged in aerial photography of land, buildings, and insurance claims, by using remote controlled sUAS to see the condition of fields, crops, ecological impact, and financial losses do to destruction by fire and other natural disasters, wi thout the need to drive over or climb on the property being so assessed. EAI has equipped each of our sUAS aircraft GoPro cameras for aerial photograph y including video and still pictures and special lens adaptations to make them very accurate in the 3 D mapping activity . By

doing so we have the abilit y to produce high

- resolution photography of remote locations that would be difficult or dangerous to reach on foot. This would be especially problematic while doing loss claim work for insurance companies. EAI exemption request would permit us to operate lightweight, unmanned (remotel y controlled in line of sight) sUAS’s in tightly controlled and limited airspace. Predetermined, specifically marked areas of operation as well as Global Positioning Satelli te (GPS) navigation maps which incorporate restricted, no fl y zones and control zones of airports, will allow EAIto operate within current safety parameters as well as the new ones being implemented. **The Extent of Relief EAI Seeks and Its Justification for Such Relief:**  **Regulation from EAI request exemption:** 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.205(b) 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417) **Unmanned Aircraft System** sUASs are seen as a better photographic platform to helicopters because these smaller devices are less expensive, they

produce less noise, and they have much less environmental impact and are less likely to cau se injury

to the public and or propert y.

# Elite Aerial Images **3210 Bird Dr -**  **Erie -**  **PA 16510 814**  **- 897**  **- 9637** 

3 I am petitioning for exemption to enable EAI to operate DJ I Phantom2, v2, sy stems, equipped with a 3 axis Zenmuse Gimbal, and a GoPro Hero 4, Black camera. This sUAS has a built in capacit y to limit the height it flies above the ground, to limit the radiu s of the distance it flies from the operator and to exclude it for Class B, C, and D airspace including No Fl y Restricted Zones. The Phantom also has the failsafe feature of the Naza

- M autopilot sy stem which means when the communication between the main controller and the transmitter is lost, the Phantom will return to the home starting point and land safel y. The above specifications meet with the Model Aircraft Operating Standards as set below:

 The petitioner will only operate its sUAS in line of sig ht of a pilot/observer and will operate at sites that are sufficient distance from populated areas within the sterile area described in the FOPM. Such operations will insure that the sUAS will not create a hazard to users of the national airspace or the p ublic.  When flying sUAS within 3 miles of an airport, airport operators will be notified and the operator will give the right of way to avoid fl yi ng in the proximity of full scale aircraft.  Maximum flight time for each operational flight will be 30 minutes

.  Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit.  The sUAS will be programmed so it will not be operated at an altitude of no more than 4oo feet AGL, and not more than 200 feet above a fixed platform from which operations are conducted.  The minimum crew for each operation will consist of the sUAS pilot and the Visual Observer.  The sUAS pilot will be an FAA licensed Private Pilot with a Second Class Medical Certificate.  The sUAS will weigh less than 55 pounds including its pay load of camera and gimbal.  The sUAS will fly

no more than 50 knots and can hover plus move horizontally and verticall y.  Given the small size of the sUAS, and the restricted airspace within which it will operate, I believe our sUAS o perations will comply with both the spirit and the rules intended by the Reform Act safet y requirements. Additionally , the fact that Iam a private pilot and hold a FFA Pilots L icense demonstrates that I have a high regard to safe operations with a throu gh understanding of the FAR’s, preflight inspections, maintenance and repair, operations within airspace, as well as being trained to high safet y standards.

# Elite Aerial Images **3210 Bird Dr -**  **Erie -**  **PA 16510 814**  **- 897**  **- 9637** 

4 As part of this request for exemption, I(EAI) give my personal assurance that all persons involved in aerial operations have completed sUAS education and training including all applicable regulations and guidance documents. I respectfully

request exemption under Section 333 to enable EAI to operate efficient, limited, low

risk commercial sUAS operations for the activities stated, respecting at all times, the space and privacy of citizens and property

as we keep our skies safe. Sincerel y yours, Douglas R. Duer Owner/Elite Aerial Images, Co. 3210 Bird Drive Erie, Penns yl vania 16510 814

- 897

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