### Docket Operations, M-30: U.S Department ofTransportation (DOT) 1200 NewJerseyAve SE, Rm W12-140 West Building Ground Floor Washington, DC 20590 Gareth John View by Video, !nc 1420 Celebration Blvd Suite 200 Celebration, FL34747 Tel: (877) 828-0508 September03 2015

RE: Exemption Request Section 333 ofthe FAA Reform Actand Part 11 ofthe Federal Aviation Regulationsfrom 14C.F.R. Part 21, 45.27(a), 45.29 (3) 

### (.c) (d) 

### (it) (f) (g) (h), 61.113 (a) & (b), 91.103, 91.119, 91.121. 91.203. 91.151 

### Following the format of FAA Exemption No. 11138 -Regulatory Docket No. FAA- 2014-048, 11 have included: PHANTOM 2VISION PLUS User Manual PHANTOM 2VISION PLUS Smart Battery Safety Guidelines PHANTOM 2VISION PLUS PilotTraining Guide

I 

### Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, !, 

### Gareth John, aprofessional V!deographer and Photographerfor the Rea! Estate Industry forthe past 10 years, am preparing this exemption request myself and would like to applyfor an exemption from the following Code of Federal Regulations (C.F.R) in orderto be allowed commercial operation of lightweight Unmanned Aircraft Systems (sUAS) for aerial imaging and video of Orlando, Kissimmee, Davenport, Clermont, Fort Myers, Cape Coral, Sarasota and Tampa, primarily but not limited to landmarks and homes listed for sale and/or rental. Ihave 2years experience in flying hobby quad coptersfor recreational purposes without incident. Ihave added a hobby grade DJI Phantom 2 PLUS quad copter (equipped with four rotors that are driven by electric motors powered by batteries, the UAS has a maximum airspeed of 32 knots) to my inventory with intentfor aerial videography/cinematography and photographyto enhance real estate listing videos and vacation rental home promotion, following 

### an exemption and approval

### by the FAA. My exemption request would permit operation of ultra-light weight, unmanned (piloted by remote control) in predetermined areas awayfrom general public, airports, heliports and vehicular traffic, under400ft. and after carefully reviewing, inspecting and examining the area of aerial observation. This would allowfor community videos and within property boundaries for individual homeowner real estate listing videoslphotos. Iwill 

### abide by all FAA requirements toensurethis exemption will provide a level of safety in accordance with existing rules and will only operate in asafe environmentthat is strictly controlled, are awayfrom power lines, elevated lights, airports and actively populated areas; and Iwill conduct extensive preflight inspections and protocols, during which safety is of the utmost importance.

14 C.F.R. Part21. Subpart H: Airworthiness Certificates 14 CFR § 91.203 Given the size, weight, speed, and limited operating area associated with the aircraftto be utilized, Iam asking exemption from 14CFRpart21, Subpart H (Airworthiness Certificates) and§91.203 (a) and (b) (Certifications required), subjectto certain conditions and limitations, is warranted and meetsthe requirementsfor an equivalent level of safety under14CFRpart 11 and Section 333 of 

### P.L. 112-95 (Section 333).

14 C.F.R. 45.27(a): location of marks: non fixed-wing aircraft. 14C.F.R. 45.29 (3) (c) (d) (e) (f)(h): Sizeof Marks Furthermore I request an exemption from §45.23 Marking ofthe aircraft because my UAS will not havea cabin, cockpit or pilot station on which_tomarkcertain wordsor phrases. Additionally two -inch lettering is difficultto place on such a small aircraft with dimensions smallerthan the minimal lettering requirement. Iunderstand the need for markings and will mark my UAS in the largest possible lettering by placing the word "Experimental" or assigned number or name (based on a request or ruling bythe FAA) on itsfuselage as required by §45.29(f) so that anyone shadowing as a spotterwill see the markings. Ialso askfor an exemption from §§91.405{a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b) Maintenance inspections may be required and should be granted sincethey only applyto aircraft with an airworthiness certificate. As a safety precaution Iwill perform a preflight inspection of my UAS before each flight as outlined in the OJI Phantom Vision Plus operating documents.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command. Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, however Ican achieve an equivalent level ofsafety as achieved by current regulations because my UAS does not carry any pilots or passengers. While helpful, a pilots' licensewill not ensure remote control piloting ski11s. The risks of operating a UAS are far lessthan the risklevels inherent in the commercial activities outlined in 14 CFR part61 ,et seq., I request an exemption from §61.113 Private Pi!ot Privl!eges and Limitations.
14 C.F.R. 91.103 (b) (1}, (b)(2}: PreflightAction.

If granted an exemption Iagree to additional safety procedures including, but not limited to: 1. Ensuring the UAS remains within a radius distance of 1000 feet from the controllerto aid in direct line of sight visual observation. 2. Operate the UAS for 3-7 minutes perflight; land my UAS according tothe manufacturer's 

### recommended minimum level ofbattery power.

23. Operate my UAS only within visual line of sight (VLOS). 4. Usethe UAS'

**g~obal** positioning system and Global Navigation Satellite System and Vison Positioning System (GPS/GLONASS) flight safetyfeature; it hovers, returns to itstake-off location and then slowly lands ifcommunication with the remote control is lost. 5. Iwill operate and will actively analyze flight data and other sources of information to constantly update and enhance my safety protocols. 6. Contact respective airports if operations will be within 5 milesto advise them of estimated t.!ight time, flight duration, etevation offlightandotherpertinentinformation. 

### 7. Always obtain all necessary permissions priorto operation. 

### 8. Have procedures in place to abortflights in the event of safety breaches or potential danger. 9. Ensure that all operational firmware and software is kept up to date at all times. Aerial videographyfor geographical awareness of real estate marketing has been around for a long time through manned fixed winged aircraftand helicopters, butfor small business, its expense has been cost-prohibitive. Granting this exemption would allow me to provide this service at a much lower cost. Further, my small UAS, when used properly, will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned 

### aircraft. The operation o1 aUASwi11 minimize eco1ogica1 damage and promote econorntc

### growth by providing information to companies looking to relocate or develop real estate in Orlando and 

### itssurroundingareas!nthestate of Florida.



### suomlttect respectfully,

Gareth John President View byVideo, Inc



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