Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

1 August	12 ,	2015

Docket O peration s ,	M

- 30 US	Department	of	T ransportation

1200 New	Jersey Avenue ,	SE

Room	W12

- 140,	West	Building	Ground	F loor Washington

, DC	20590

- 0001

Re:	Pe tition	for	exemption	under	FAA	Modernization	and	Reform	Act	of	2012	(P.L.

112

- 95),	S ection	33

Dear Sir	or	M adam:

Pursuant to	Section	333	of	the	FAA	M odernization	and Reform	A ct	of	2012(FMRA) and	14	CFR	Part	II,	Alexandra	Hoover	hereby applies	for	an	exemption	from	Federal

Aviation	R egulations	(FARs)	listed	below	under	“Basis	f or	Petit ion”. Exemption	is being	sought	in	order	to	allow	Alexandra	Hoover	to	operate	her	unmanned	aircraft systems	(UAS)	commercially	for	the	purpose	of	aerial	videography	and photography, precision agriculture	and	environmental	management	and	analysis,

a erial	inspection	of	land	and structures ,	journalism	and	news	gathering,	real	estate marketing,	and	closed	set	motion	picture	and	television	film	making	and	production.

INTRODUCTION	OF	THE	PETITIONAR

Alexandra	Hoover	provides	services	to	her	clients	to	e nhance	a	variety	of	their business	and	personal objectives by	providing digital photography ,	videography, cinematic	consulting	and	other	types	of	digital	imaging	and	related	services.

Alexandra	Hoover possesses over	15	years	of	experience	in	recreational/h obby aspects	of	R/C	aviation,	photography,	videography	and	UAS piloting,	photo	and video	editing,	and	training	services.	Alexandra’s	objective	is	to	provide	pro fessional quality	digital	imaging,	editi ng	and	analy sis	for	a	variety	of	commercial, p ublic, pri vate	and	not	for	profit organizations and	individuals,	including	but	not	limited	to:

• Closed	set	motion	picture	and	television	filming	and	production

• Photography	and	videography	for	journalism	and	news	gathering	purposes

• General	aerial	photography	and	insp ection	of	land,	structures	and construction	projects

• Real	estate	marketing	photography	and	videography

• Digital imagery and	data	acquisition	for	precision	agriculture,	environmental management	and	scientific	analysisPetition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

2 UNMANNED	AERIAL	SYSTEMS

DJI Inspire	1,	DJI	Phantom	2,	DJI	Spreading	wings	S1000 + ,	DJI	Spreading	wings S900,	DJI	spreading	wings	S800	EVO

Alexandra	Hoover	seeks	an	exemption	to operate	DJI	Inspire	1,	DJI	Phantom	2,	DJI Spreading	wings	S1000 + ,	DJI	Spreading	wings	S900,	DJI	spreading wings	S800	EVO for	compensation	or	hire	within	the	National	Air	Space	(NAS). The DJI	Inspire	1,	DJI Phantom	2,	DJI	Spreading	wings	S1000 + ,	DJI	Spreading	wings	S900,	DJI	spreading wings	S800	EVO are	all	vertical	takeoff	and	landing	(VTOL)	unmanned	aircraft. The DJI	Phantom	2	is	a	four

- rotor	quad

- copter	that	has	a	maximum	gross	weight	of approximately 3 p o unds	3	ounces,	including	Zenmuse	H3

- 2D	gimbal	and	go

- pro camera	systems,	and	a	maximum	speed	according	to	the	manufacturer	of approximately 33.5	miles	per	h our.	The	DJI	Inspire	1	is	a	four

- rotor	quad

- copter that	has	a	maximum	gross	weight	of	6	pounds	7.5	ounces,	including	onboard	gimbal, camera	systems,	and	batteries,	and	a	maximum	speed	of approximately 48.5	miles per	hour. DJI	spr eading	winds	S1000+	is	an	e ight

- rotor octo

- copter	and has	an approximate	w e ight	of	9	pounds	11.21	ou nces.	DJI	spreading	wings	S900 is	a	six

rotor	hexa

- coptor	and	has	an	approximate	weight	of	7	pounds	4.4	ounces.	DJI spreading	wings	S800	EVO is	a	six

- rotor	hexa

- coptor	and	has	an	appr oximate weight	of	8	pounds	2.51	ounces.	Each	of	the	above	described	UAS	are	equipped	with

rotors	and propellers driven	by	lithium	polymer	battery	powered	electric	motors. Each	are	also	equipped	with	the	industry	standards	in	GPS,	electronics,	guidance,

pro pulsion,	telemetry,	safety	features	and	ease	of operator functionality.	Detailed

i nformation	regarding	each	UAS	is at tached	in	Appendices	A	through	E

.

It	should	be	noted	that	these	particular	UAS	h a ve	each	been	approved	in	con nection with	prior	Section	3 33	Grants	of	E xemption.	Each	UAS	is	recognized	in	the	UAS industry	as	a	leading	example	of	precision,	quality,	performance

, durability	and technological innovation.	These	UAS	will	offer	Alexandra	a	range	of	options	for

matchin g	the	desired	flight	character istics and	technology	with	the	desired	tasks, environmental	conditions,	and	navigational	demands,	thus	assuring	overall	safety and	completion	of	assigned	work	product s and	desire d results.

BASIS	FOR	PETITION

Alexandra	Hoover,	pursuant	to	the	provisions	of	the	Federal	Aviation	Regulations (14	C.F.R.	Section	11.61)	and	the	FAA	Modernization	and	Reform	Act	of	2012 (FMRA),	Section	333,	Special	Rules	for	Certain	Unmanned	Aircraft	Systems,	hereby petitions	the	Admin istrator	to	commercially	operate	the DJI	Inspire	1,	DJI	Phantom 2,	DJI	Spreading	wings	S1000 + ,	DJI	Spreading	wings	S900,	DJI	spreading	wings	S800

EVO in	the	National	Airspace	S ystem	(NAS),	and	for exemption	from	the requirements	of	14	C.F.R.	Sections	61.11 3(a)&(b), 91.7(a),	91.119(c),	91.121, 91.151(a)(1),	91.405(a),	91.407(a)(1),	91.409(a)(1)&(a)(2),	and	91.417(a)&(b).Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

3 The	granting	of	the	exemption	from	the	above	listed	FARs	will	al l ow	Alexandra Hoover	to	conduct	commercial	operations	of	her	UAS	to	effic iently	and	safely	deliver high

- definition	digital	imagery	and	other	acquired	data	to	her	clients	and	customers

more	cost

- effectively than	traditional	methods.	Employing	UAS	technology	can	also be	safer	for	workers	because	in	many	instances	the	workers	may avoid	dangerous or	precarious	hazards	or	physical	positions	involving	high	risk	of	injury.	Unmanned

Aerial	S ystems	also	enable	safe	inspection	of difficult to	reach	or	environmentally sensitive	locations	without	the	use	of	heavy	trucks,	cranes,	booms	or	ot her equipment	requir ing	greater	expense	or	creating undesirable	environmental impacts.		In	general,	UAS	operated	by	Alexandra	Hoover	will	economically	benefit her	customers	by	acquiring	important	and	aesthetic	digital	imagery	and	data	safely and	less	expen sively	for	a	wide	variety	of	applications.

Alexandra	Hoover	proposes	to	use	UAS	that	are	multi

- rotor	craft	weighing	a maximum	of	21.75	pounds	fully	loaded,	or	less,	which	fly	at	a	speed	of	48.5	miles	per hour,	or	less.	The	craft	are	all equipped with	bui lt	in	safety	features	including sophisticated	navigation	controls	and	fail

- safe	technology	to	assure	safe	and predictable	aerial	maneuvers,	take

- off	and	landing.

Proposed	operations	will	be	conducted	under	controlled	conditions	in	airspace	that

is	limite d,	predetermined,	access	controlled	and	under	constant	monitoring	before and	during	flight.	Operations	contemplated	under	the	exemption	will	be	subject	to strict	operating	parameters	to	ensure	at	least	an	equivalent	level	of	safety	to currently	authorized and/or	exempted	operations

.

NAME	AND	ADDRESS	OF	THE	PETITIONER

The	name	and	address	of	the	petitioner	and	point	of contact is:

Alexandra	Hoover

4042	Garth	Road Crozet,	Virginia	22932 (207)	272

- 6059

Email: a hoover0915@gmail.com

OPERATING	DOCUMENTS

The	comprehensive	operations	manuals/user	guides/safety	guides	and	other detailed	information	provided	by	the	UAS	manufactures	are	attached to	this	petition as	Appendix	“A”	(DJI	Inspire	1)	Appendix	“B”	(DJI	Phantom	2)	Appendix	“C ” Spreading	wings S1000+)	Appendix	“D ”	(DJI	Spreading	wings	S900) and Appendix

“E ”	(DJI	Spreading	wings	S800	EVO).	The	appendices	are	comprehensive	and

current	for	ea ch	UAS,	and	offer	a	complete	description	of	each	aircraft,	including operating	features	and	protocols,	specifications,	maintenance,	recommendations and	guidance,	safety	and	navigation	information,	battery	maintenance	an d	safety, aircraft	controls, gimbals and	more.Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

4 Attached	as	Appendix	“F ”	is	Alexandra	Hoover’s	pre

- flight	Checklist	and	In

- flight safety	checkli st;	Appendix	“G ”	contains	Alexandra’s	flight	log	forms	and	monthly

maintenance log	form;	Appendix	“H” is	Alexandra’s	Motion	Picture	and	T elevisio n Operations	Manual	and Flight Operations Manual	for	use	in	closed	set	motion picture	and	tel evision	filming	and	production.

THE	PILOT	IN	COMMAND	(PIC)

The	PIC	will:

• Hold	a	current	FAA	Sport	P ilot	certificate	or	higher	FAA	pilot	certification

• Hold	a	valid third	class	medical	certificate	or	valid	drivers	license

• Have accumulated and	logged,	in	a	manner consistent with	14	CFR	61.51	(b), a	minimum	of	25	hours	of	total	time	as	a	UAS	rotorcraft	pilot	and	at	least	10 hours	logged	as	a	UAS	pilot	with	similar	UAS type.

• Have	accumulated	and	logged	a	minimum	of	five	hours	as	a	UAS	pilot	with the	make	and	model	of	UAS	to	be	utilized	for	operations under	the	exemption

and	three takeoffs and	landings	in	the preceding 90	days	prior	to	an operation.

• As	noted	below	in	“o perating parameters ,	limitations,	cond itions,	and requirements”,	the	O perator	will	not	allow	a	PIC to	operate	unless	the	PIC

has demonstrated	that	the	PIC	is	able	to	safely	operate	the	UAS	in	a	manner

consistent with	how	the	UAS	will	be	operated	under	the exemption,	including evasive	and	emergency maneuvers and maintaining appropriate	distances from	people,	vessels,	vehicles,	and	structures.

Visual	O bservers	must	have	demonstrated	that	they	understand	the	conditions	and limitations	of	flight	noted	in	the same	section	which	follows	immediately	below.

OPERATING	PARAMETERS,	LIMITATIONS,	CONDITIONS	AND	REQUIREMNTS

Grant	of	the exemptions will	be	subject	to	the	following	conditions,	which	provide	at least	an	equivalent	or	higher	level	of	safety	than	under	th e	current	conditions.	These conditions	are	derived	from	Exemptions	11062 through 11067,	11080,	11109	and 11110,	and	others.

For	the	following	listing,	the Petitioner Alexandr a	Hoover	is	referred	to	as	the

O perator.

1. O p erations	authorized	by	the	grant w i ll	be	limited	to	the	UAS	described above	and	manufactures’	upgraded	versions

.

2. The	UAS	weigh	21.75	pounds	or	less,	including	batteries,	gimbals, camera systems	and	other	necessary attachments.Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

5 3. The	UA	will	be	flown	at	a	maximum	ground	speed	of	50	miles	per hour.	In	no case	will	a	UA	be	operated	at	airspeeds	greater	than	the	maximum	UA airspeed	recommended by	the aircraft	manufacturer.

4. The	UA	will	be	operated	at	an	altitude	of	no	more	than	400	feet	above ground	level (AGL).	Altitude	will	be	reported	in	fee t	AGL.

5. The UA	will	be	operated	within	Visual	Line	of	S ight	(VLOS)	of	the	PIC	at	all times.	This	requires	the	PIC	to	be	able	to	use	human	vision	unaided	by	any device	other	than	corrective	lenses,	as	specified	on	the	PIC’s	FAA

- issued

medical	certificate or	U.S.	driver’s	license.

6. All operations	will	utilize	a	Visual	O bserver	(VO).	The	UA	will	be	operated within	the	visual	line	of	sight	(VLOS)	requirement	as	long	as	the	PIC	always

maintains VLOS capability .	The	VO	and	PIC	will	be	able	to	communicate

verba lly	at	all	times.	Electronic messaging or	texting	will	not	be	permitted during	flight	operations.	The	PIC	will	be	designated	before	the	flight	and	will not	transfer	his	or	her	designation	for	the	duration	of	the	flight.	The	PIC	will

ensure	that	the	VO	can perform	the	functions	and	duties	required	of	the	VO.

7. The	operating	documents	and	the	grant	of	exemption	will	be accessible during	UAS	operations	and	made	available	to	the	Administrator	upon request.	The O perator	ma y	update	or	revise	Her operating	documen ts.	It	will

be	the O perator’s	responsibility	to	track such	revisions	and	present	updated and	revised	documents	to	the	Administrator	or	any	law	enforcement	official upon	request.	If	there	is	a discrepancy between	the	exemption	conditions

and	limitations	and the	procedures	outlined	in	the	operating	documents,	the conditions	and	limitations	in	the	grant	of	exception	take	precedence	and	will

be	followed. Otherwise the	O perator	will	follo w	the	procedures	outlined	in

Her operating	documents.	If the	O perator	deter mines	that	any update or revision	would	affect	the	basis	upon	which	the	FAA may	grant	this exemption,	the	O perator	will	petition	the	FAA	for	amendment	to	the exemption.

8. Any	U AS	that	has	undergone	maintenance or	alterations	that	affect	the	UAS flight	char acteristics	or	operation,	e.g.	replacement	of	an	essential	flight component,	will	undergo	a	functional	test	flight	prior	to	conducting	further operations.	Functional	test	flights	will	be	conducted	by	a	PIC	with	a	VO	and

w ill	remain	at	least	500	feet	fro m	o ther	people.	The	functional	test	flight	will be	conducted	in	such	a	manner	so	as	not	to	pose	an	undue	hazard	to	persons and	property.

9. The	operator	will	be	responsible	for	maintaining	and	inspecting	the	UAS	to ensure	that	it	is	in	a	condition	for	safe	ope ration.Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

6 10. Prior	to	each	flight	the	PIC	will	conduct	a	pre

- flight	inspection	and	determine that	the	UAS	is	in	a	condition	for	safe	flight.	The	pre

- flight	inspection	will account	for	all	potential	discrepancies,	e.g.	inoperable	components,	items,	or equipmen t.	If	the	inspection	reveals	a	condition	that	affects	the	safe operation of	the	UAS,	the	aircraft will	be	prohibited	from	operating	until	the necessary	maintenance has	been	performed	and	the	UAS	is	found	to	be	in a condition	for	safe	flight.

11. The	operator will	follow the	UAS	manufactures’	maintenance ,	overhaul, replacement,	inspection,	and	life	limit	requirements	for	the	aircraft	and aircraft	components.

12. Each	UAS	operated	under	the	exemption	will	comply	with	all	manufacturer safety bulletins.

13. The PIC	wi ll	posses	at	least	a	Sport	Pilots	Certificate	and	a	current	Third

Class	FAA	A irman Medical	C ertificate.	The	PIC	will	also	meet	the	flight review	requirements	specified	in	14	CFR	61.56.

14. The O perator	may	not	permit	any	PIC	to	operate	unless	the	PIC	has

demonstrated that	the	PIC	is	able	to	safely	operate	the	UAS	in	a	manner

consistent with how the	UAS	will	be	operated	under	the	exemption, including	evasive	and	emergency maneuvers and	maintaining	appropriate distance	from	people,	vessels, vehicles ,	and	str uctures.	PIC	qualification flight	hours	and	currency	will	be	logged	in	a	manner	constant	with	14	CFR Section	61.51(b). Flights fo r	the	purposes	of	training	the	O perators

, PICs

, and	VOs	(training,	proficiency,	and	experience

- building) and	determining

the	PI Cs ability to safely	operate	the	UAS	in	a	manner consistent with	how the	UAS	will	be	operated	under	the	exemption	will	be	permitted	under	the terms	of	this	exemption. However ,	training	operations	will only be conducted	during	dedicated	training	sessions.	During	training,	proficiency and	experience	building	flights,	all	persons	not	essential	for	flight	operations

are	t o be	considered	non

- participants	in	accordance	with	14CFR	Section

91.119

15. UAS	operations	wi ll	not	be	conducted	during	night,	as	defined	in	14	CFR Section	1.1.	All	operations	will	be	conducted	under Visual	Meteorological

C onditions	(VMC).	Flights under	Special	Visual	Flight	R ules	(SVFR)	will	not

be	conducted.Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

7 16. The	UA	will	not	operate	within 5	nautical	miles	of	an	airport reference point (ARP)	as	denoted	in	the	current	FAA	Airport/Facility	Directory	(AFD) or,	for airports not	denoted	with	an	ARP,	the	center	of	the	airport symbol	as denoted	on	the	current	aeronautical	chart	published	by	the	FA A,	unless	a letter	of	agreement	with	that	airports management is	obtained	or	otherwise permitted	by	a	COA	issued	to	the	exemption	holder.	The	letter	of	agreement with	the	airport	management	will	be	made	available	to	the	Administrator	or any	law	enforcement official	upon	request.

17. The	UA	will	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet horizontally	fro m	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from

the	PIC.

18. If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UA will	return	to

a	pre

- determined	location	or	recovery	point	within	the	private	or

controlled

- access	property.

19. The	PIC	will	abort	the	flight	in	the	event	of	unprecedented obstacles or emergencies

.

20. The	PIC	will	not	begin	a	flight	unless	(considering	wind and forecast weather conditions)	there	is	enough available power	for	the	UA	to	conduct	the intended	operation and	still	maintain	a	reserve battery power	of	no	less	than
25%.

21. The	operator	will	apply	for	and	obtain	an	Air	Traffic	Organization	(ATO)

issued Certificate	of	Waiver	or	Authorization	(COA)	prior	to	condu cting	any operations	under	the	Grant	of	E xemption.

22. All	aircraft	operated	in	accordance	with	the	exemption	will	be	identified	by serial	number	or	equ ivalent ,	registered	in	accordance	with	14	CFR	p art	47, and	have	identification	(N

- number)	markings	in	accordance	with	14	CFR part	45,	subpart	C.	Markings	will	be	as	large	as	practical.

23. Documents used	by	the	O perator	to	ensure the	safe	operation	and	flight	of the	UAS	and	any	documents	required	under	1 4	CFR	Sections	91.9	and

91.203	will	be	available	to	the	PIC	at	the	Ground	Control	Station	of	the	UAS at	any	time	the	aircraft	is	operating.	These	documents	will	be	made	available to	the	Administrator	or	any	law	enforcement	official	upon	request.

24. The	UA	w ill	remain	clear	and	give	way	to	all	manned	aviation	operations	and

activities	at	all	times.

25. The	UAS	will	not	be	operated	by	the	PIC	from	any	moving	device	or vehicle.Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

8 26. All	flight	operations	will	be	conducted	at	least	500	feet	from	all	non participating	persons,	vessels,	and structures unless:

a. Barriers	or	structures	are	present	that sufficiently protect	non

participating	persons from	the	UA	and /or	debris	in	the	event	of an accident.	The	operator	will	insure	that	non

- participating	persons	remain under	such	protection.	If	a	situation	arises	where	non

- participating persons	leave	such	protection and	are	within	500	feet	of	the	UVA,	flight operations	will	cease	immediately	in	a manner	insuring	the	safety	of

non

- participating	persons;	and,

b. The	owner/controller	of	any	vessels, vehicles ,	or structures has	granted permission for	operating	closer	to	those	objects	and	the	PIC	has	made	a safety	assessment	of	the risk	of	operating closer	to	the objects and determined	that	it	does	not	present an	undue	hazard.	The	PIC,	VO,

O perator

, trainees	or	essential	persons	will	not	be	considered	non

participating	persons	under	the	exemption.

27. A ll	operations	shall	be	conducted	over	private	or	co ntrolled

- acc ess	property with	permission	fro m	the l and	owner/controller	or	authorized representative .	Such	permission	will	be	obtained	for	each	flight.

28. Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or

vertical boundaries of	th e	operational	area	as	defined	by	the	applicable	COA will	be	reported	to	the	FAA’s	UAS	Integration	Office	(AFS

- 80)	within	24

hours.	Accidents	wi l l	be	reported	to	the	National	Transportation	Safety Board	(NTSB)	per	instructions	contained	on	the	NTSB	Web	site : www.ntsb.gov

.

29. The O perator	will	engage	in	closed

- set	motion	picture	and	television	filming and	production	in	accordance	with	the	conditions	enumerated	and described	in	the	flight	operations	and	procedures	manual	(FOPM ),	and approved	motion	picture	and	television	operation	manual	(MPTOM)	to	be

attached to	this	petition	as	appendix	“H ”.

30. At	least	3	d ays	before	aerial	filming,	the	O perator	of	the	UAS	which	is	subject to	this	exemption	will	submit	a	written	Plan	of Activit ies to	the	local	Flight Standards	District	Office	(FSDO)	with	jurisdiction	over	the	area	of	proposed filming.	The	3

- day	notification	may	be	waived	with	the	concurrence	of	the

FSDO.	The pla n	of	activities	must	include	at	least	the	following:

a. D ates	and	time s	for	all	flights;

b. N ame	and	phone	number	of	the operator for	the	UAS	aerial	filming conducted	under	the	grant	of	exemption;

c. N ame	and	phone	number	of	the	person	responsible	for	the	on

- scene operation	of	the	UAS;

d. M ake,	model,	and	serial	number	or	N

- Number	of UAS	to	be	used

e. N ame	and	certificate	number	of	UAS	PICs	involved	in	the	aerial	filming;Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

9 f. A statement	that	the	operator	has	obtained	permission	from	property owners	and/or	local	officials	to	conduct	the	filming	production	event;	the list	of	those	who	gave	pe rmission must	be	made	available	to	the

I nspector	upon	request;

g. S ignature	of	the exemption holder	or representative ;	and

h. A description	of	the	flight	activity,	including	maps	or	diagrams	of	any city,	town,	county,	and/or	state	over	which	filming	will	be	conducted	and the	altitude	essential	to	accomplish	the	operation.

31. F light	operati ons	may	be	conducted	closer	than 500	feet	f rom	participating persons	consenting	to	be	involved	and	necessary	for	the	filming production, as	specified	in	the	MPOTM.

THE	PUBLIC	INTEREST

The	public	interest	in	granting	this	exemption	request	is	served	by,	among	others, the	following:

• T he	use	of	UAS	improves	public	safety	and	reduces	risk	by	alleviating	the public’s	exposure	to	danger	and	emissions	associated	with	conventional aerial	methods	(full	size	aircraft)	that	are	very	heavy,	fast,	carry passengers
, and	contain flammable fuel	and cargo.

• A myriad of	ecological	ad	environmental	benefits	and	improved	economic efficiency	and	scientific	information	and	data	acquisition	are	potential	public benefits	accomplished	through	the	use	of	UAS	for	precision	inspections	of

infrastructure	and	indus trial	plant	equipment	such	as	energy pipelines

, power	lines,	smokestacks,	towers,	and	other	man

- made structures ,	which	can be	observed	and	later	analyzed safely ,	accurately	and	un

- obtrusively

.

• Commerce	can	be	improved	through	data	and	image	acquisition	for real estate,	construction,	precision	agriculture,	surveying	and	other applications of	UAS	technology.

• The	visual	arts	such	as	film,	photography	and	television	are	improved through exciting	and	beautiful	images	captured	via	the	versatile	aerial platform	UA S	provides,	which	benefits	the	collective	cultural	and	aesthetic demands	and	desires	of	an	appreciative	public.

• UAS	may	be	an	exceptional	tool	for	journalists	and	all	manner	of	news gathering	and	reporting	media,	to	serve	the	public	good	in enhancing

accu rate	dissemination	of	news	worthy and	relevant	information	to

interested	citizens.

• Approval	of	this	exemption	will	provide	immediate	employment opportunities	for	individuals	and	businesses	whose	livelihood	may	be directly or	indirectly	improved	though	care er opportunities and	job creation in	a	growing	technology	sector	of	the	economy.Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

10 • Congress	has	established	a	national	policy	that	favors	prompt	integration	of UAS	into	the	NAS,	provided	that	judicious	and	reasoned	agencies	and	officials guide	the	process prudently	and	with	due	emphasis	on	public	safety	and efficiency.	The	granting	of	this	petition	for	exemption	will	serve	this	public policy	mandate	and	result	in	the	attendant	benefits	perceived	by	this	policy.

SUMMARY	FOR	PUBLICATION

For publication	in the Federal	R egister ,	Alexandra	Hoover	provides	the	following

summary:

An	exemption	is	requested	from	the	following	regulations	in	order	to	allow commercial	operation	of	her	Unmanned	Aircraft	Systems	involving	aerial applications	such	as	closed

– set	motion picture	and	television	filming,	general	aerial photography	and	videography	for	inspection	of	land,	structures,	construction projects	and	real	estate,	videography	and	photography	for	journalism	and	news gathering	purposes,	digital	imagery	and	data	acquisit ion	for	precision	agriculture, environmental	management,	and	scientific	analysis.

14	CFR	Section	61.113	(a)	and	(b) 14	CFR	Section	91.7	(a) 14	CFR	Section	91.119	(c)

14	CFR	Section 91.212 14	CFR	Section91.151	(a)	(1) 14	CFR	Section	91.405	(a)

14	CFR Section	91.407	(a)	(1) 14	CFR	Section	91.409	(a)	(1)	and	(a)(2) 14	CFR	Section91.417	(a)	and	(b)

CONCLUSION

Alexandra	Hoover	seeks	an exemption ,	pursuant	to	14	CFR	Section	11.61	and Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA),	whic h will permit	Alexandra	Hoover	to	safely	operate	UAS	commercially	for	the	purposes	and operations	described	herein.	In granting	this	P etition,	the	FAA	Administrator	will	be fulfilling	the	congressional	mandate	and	policy	of	FMRA,	while	also	providing	a sig nificant	number	of	benefits	to	the	public,	the	environment	and	the	economy.	The exemption	will	enable	Alexandra	Hoover	to	utilize	her	technological	expertise, advanced	aircraft	knowledge,	and entrepreneurial vision	to	enhance	the	safety, beauty	and	economi c	progress	of	the	public	and	private	sectors	and	advancing	the interest	of	society	at	large.

Alexandra	Hoover	respectfully	requests	that	the	Administrator	grant	this	Petition for	an	exemption from	the	requirements	discussed therein ,	and	permit	Alexandra to
operate commercially	the	Unmanned	Aircraft	S ystems	in	the	aerial	operations	set

forth	herein.Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra Hoover

11 Thank	you	for	your	consideration.

Sincerely,

/s/ 

### Alexandra	Hoover

Alexandra	Hoover

ATTACHMENTS (Appendix A	through E files are too	large	to	upload	to	the	regulations	docket,	please accept	thes e	links	to	the	documents	online)

Appendix	A

– Manual	and	Safety	guide	for	the	Inspire	1
http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

Appendix	B

– Manual	and	Safety	Guide	for	the	Phantom	2
http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.8_ en.pdf

Appendix	C

– Manual	and	Safety	Guide	for	the	Spreading	Wings	S1000+
http://download.dji

innovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

Appendix	D

– Manual	and	Safety	Guide	for	the	Spreading	Wings	S900
http://download.dji

- innovations.com/downloads/ s900/en/S900_User_Manual_v1.2_en.pdf

Appendix	E

– Manual	and	Safety	Guide	for	the	Spreading	Wings	S8 00	EVO
http://download.dji

innovations.com/downloads/s800evo/en/S800_EVO_User_Manual_v1.10_en.pdf

Appendix	F

– Pre

- Flight	Checklist	and	In

- Flight	Safety	Checklist

Appendix	G

– Flight	Log	forms	and	Maintenance	Log	forms

Appendix	H

– Motion	Picture	and	Television	Operation	Manual