May 18, 2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave.

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation 

Regulations 

Dear Sir or Madam: 

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

Act"), Rod Coll on behalf of Eagle Eye Aeronautical Imaging LLC (the "applicant"), the 

operator of Unmanned Aircraft Systems ("UAS") seeks an exemption from the Federal Aviation 

Regulations ("FARs") to allow for commercial operation for aerial imaging and video of Real 

Estate for Marketing and inspections of vertically developed structures such as Wind Turbines, 

Cell Towers, Power lines and Aerial Imagery of Agricultural lands to aid rural farmers with 

crop analysis. 

Applicant:

Eagle Eye 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 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) 
Extent of relief I seek, and reasons why:

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 FAA 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 equivalent 

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 FAA 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 Training". 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 91.113 (a) and (b) 

I can achieve an equivalent level of safety as achieved 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 altitude 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 documents. 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 working condition before initiating each flight. 

Rod Coll is seeking relief from all FARs 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 UAS’ 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 obtain 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 battery life and 

flights will be terminated within 25% of battery life remaining. Given the size, weight, speed, 

and limited operating area associated with 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 Traffic Control or the 

airport 

manager has been made and authorized.
2) I land my UAS prior to manufacturer recommended minimum 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 lost. 

5) I actively analyze 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 always obtain all necessary permissions 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 buyers and sellers a higher level of 

service. For a buyer a higher level of marketing and advertising is achieved, appealing to more 

buyers, resulting in a quicker sale of their home. Quicker home sales also helps accelerate the 

economy as a whole. Buyers 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 buyer, but it benefits the general public because it is much more efficient 

than traditional ways of using a plane or helicopter to achieve the same result. We 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 you for your consideration,

Rod Coll