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Vertical Imagery LLC Section 333 Petition UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: VERTICAL IMAGERY LLC FOR AN EXEMPTION SEEKING RELIE F FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REG ULATIONS (14 CFR) PART 21 SECTIONS; § 61.113(a) and (b), 91.7(a) , 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b). CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on April 13, 2015 Vertical Imagery LLC Ryan P. Corey P.O. Box 1345 2275 Dead Indian Memorial Road

Ashland, OR 97520 (541) 488-2880 ryan@timberlandhelicopters.comPage 2

Vertical Imagery LLC Section 333 Petition TABLE OF CONTENTS Glossary of abbreviations 3 Summary 4 Introduction and interests of the petitioner 4 Background 5 Proven operational history of DJI T600 in the NAS 6

Basis for petition 7 Name and address of petitioner 7 Specific sections of C.F.R. from which Vertical Imagery seeks exemption 8

Reasons why granting Vertical Imagery's request would be in the public interest 10

Flight Operations 11 Flight operations of Vertical Imagery's UAV is limited to line of sight of the PIC with a
Visual Observer 12

Operation of Vertical Imagery’s UAV will be conducted pursuant to the Standard Operating Procedures manual 12

Conclusion 13Page 3

Vertical Imagery LLC Section 333 Petition GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
ATC Air Traffic Control
COA Certificate of Authorization
FAA Federal Aviation Administration
FAR Federal Aviation Regulation NAS National Airspace System
PIC Pilot In Command
Section 333 FAA Modernization and Reform Act of 2012, Section 333 SOP Standard Operating Procedures
UAS Unmanned Aircraft System
UAV Unmanned Aerial Vehicle
UH Unmanned Helicopter
VFR Visual Flight Rules VMC Visual Meteorological Conditions
VO Visual Observer
VTOL Vertical Take Off and LandingPage 4

Vertical Imagery LLC Section 333 Petition SUMMARY Vertical Imagery LLC seeks exemption from the requi rements of 14 C.F.R. §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405 (a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b), to operate an Unmanned Aircraf t System pursuant to Section 333
of the FAA Modernization and Reform Act of 2012. In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Vertical Imagery LLC's operation of the DJI T600 "Inspire 1" Unmanned Helicopter meets the conditions of FMRA Section 333 and therefore, will not require an
airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. This exemption will permit Vertical Imagery LLC to opera te an Unmanned Aircraft System for the commercial purpose of conducting aerial data co llection and research within the National Airspace System.

INTRODUCTION AND INTERESTS OF THE PETITIONER Vertical Imagery LLC (Hereinafter referred to as “ Vertical Imagery”) is owned and managed by professional, highly experienced commerc ial helicopter pilots who are Part 133, 135, and 137 current. Vertical Imagery's pilot s have an extensive history of power line and utility patrol, wildlife survey, electroni c news gathering, search & rescue, and firefighting work across the Pacific Northwest. Ver tical Imagery has recently acquired and been flight testing a DJI Inspire 1 Unmanned He licopter which it plans to use for commercial operations including power line and publ ic utility inspections, wildland fire patrols, aerial surveys, electronic news gathering, and aid in search & rescue operations. Vertical Imagery's lead pilot on the pr oject has over 2000 hours helicopter flight time, as well as over 20 years experience an d thousands of hours of UAV flight time. Vertical Imagery plans to work side by side w ith its sister company to diversify their fleet of aircraft with an unmanned helicopter in order to meet the needs of a continually evolving market while striving for an e ver increasing level of safety to their employees and customers.Page 5

Vertical Imagery LLC Section 333 Petition BACKGROUND Vertical Imagery seeks an exemption to operate a D JI model T600 unmanned helicopter known as the "Inspire 1" for compensatio n or hire within the national airspace system. The Inspire 1 is comprised of a 4 rotor hel icopter with attached HD camera system and a transportable ground station. The Insp ire 1 UH has a maximum gross weight of approximately six and a half pounds (6.5 lbs.) and the following technical and operational specifications:

Weight (Battery and Camera included) .............. ................... 6.5 lbs.
Dimensions ........................................ ................................... 17.3" x 17.8" x 11.9" Hover Accuracy (GPS Mode)
Vertical ......................................... .............................. 1.6 ft.
Horizontal ....................................... ............................ 8.2 ft. Max Angular Velocity
Pitch ............................................ ............................... 300°/sec.
Yaw .............................................. .............................. 150°/sec. Max Tilt Angle .................................... ................................... 35° Max Ascent Speed .................................. .............................. 16 ft./sec. Max Descent Speed ................................. ............................. 13 ft./sec. Max Air Speed .................................... ................................. 49 mph Service Ceiling ................................... ................................... 14,500 ft. Max Flight Time ................................... ................................. 18 min. approx.
Motor Model ....................................... ................................... DJI 3510
Rotor Blade Model ................................. ............................... DJI 1345 Operating Temperature Range ....................... ...................... -10° to 40° C Supported Battery ................................. ................................ DJI Intelligent Ba ttery Type .............................................. ........................................ 6S Lithium Polymer Capacity Standard Battery ................................. ....................... 4700 mAh, 22.2 V Optional Battery ................................. ........................ 5700 mAh, 22.8 VVertical Imagery LLC Section 333 Petition

Operating Frequency

................................................... .........

EIRP ..............................................

.......................................

The Inspire 1 UH that will be operated by accordance with 49 U.S.C. 44103, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, and Registration Marking

.

Figure 1: DJI T600 "Inspire

P ROVEN OPERATIONAL HISTORY OF Many DJI T600's are currently operating safely
commercial UAV's. The UH has onboard stability systems, compass, grou nd sensing sonic altimeters, and GPS. All of these allow the U H to hover with pinpoint precision and also take off and land autonomously. There is a fai lsafe built into the system allowing
the UH to retur n to a predetermined point
altitude in the event of a control link failure bet ween the aircraft and PIC. automatically return home when the battery has reached a predeter mined level, which
ensures the aircraft will land before leader in UAS technology and

Section 333 Petition ................................................... ......... 2.4~2.483 GHz
5.725~5.825 GHz
EIRP ..............................................

....................................... 20 dBm @ 2.4G 13 dBm @ 5.8G that will be operated by Vertical Imagery will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R. Part 47,

, and marked in accordance with 14 C.F.R. Part 45, Identification

1"

ROVEN OPERATIONAL HISTORY OF DJI T600 IN THE NAS

are currently operating safely within the NAS both as hobby and The UH has onboard stability systems, compass, grou nd sensing sonic altimeters, and GPS. All of these allow the U H to hover with pinpoint precision and also take off and land autonomously. There is a fai lsafe built into the system allowing

n to a predetermined point (known as "home") at a predetermined
altitude in the event of a control link failure bet ween the aircraft and PIC.

return home when the battery has reached a predeter mined level, which
ensures the aircraft will land before the battery level becomes critical. DJI leader in UAS technology and also makes several other models which have logged Page 6

GHz
5.725~5.825 GHz 20 dBm @ 2.4G 13 dBm @ 5.8G will be registered in , as well as 14 C.F.R. Part 47,

Identification

NAS both as hobby and The UH has onboard stability systems, compass, grou nd sensing sonic altimeters, and GPS. All of these allow the U H to hover with pinpoint precision and also take off and land autonomously. There is a fai lsafe built into the system allowing at a predetermined

It will also return home when the battery has reached a predeter mined level, which
DJI is the world which have loggedPage 7

Vertical Imagery LLC Section 333 Petition countless hours across the world with great success , giving DJI a reputation for some of the best technology, popularity, and reliability in the industry.

BASIS FOR PETITION Petitioner, Vertical Imagery, pursuant to the prov isions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Moderni zation and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Air craft Systems, hereby petitions the Administrator for an exemption from the requirement s of 14 C.F.R. §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1) , 91.409(a)(1) & (2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuan t to Section 333 of the FAA
Modernization and Reform Act of 2012. In considerat ion of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Vertical Imagery's operation of the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness ce rtificate in accordance with 14 C.F.R. Part 21, Subpart H. In accordance with 14 C.F.R. § 11.81, Vertical Imagery provides the following information in support of its petition fo r exemption:

NAME AND ADDRESS OF THE PETITIONER Vertical Imagery LLC
P.O. Box 1345 Ashland, OR 97520

The point of contact for Vertical Imagery's petitio n and specific contact information is as
follows:

Ryan P. Corey Vertical Imagery LLC
P.O. Box 1345 Ashland, OR 97520 (541) 488-2880 ryan@timberlandhelicopters.comPage 8

Vertical Imagery LLC Section 333 Petition THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH VERTI CAL IMAGERY
SEEKS EXEMPTION 14 C.F.R. § 61.113(a) & (b): Private pilot privileg es and limitations: Pilot in
command. Sections 61.113(a) & (b) limit private pilots to n on-commercial operations. Because the UAV will not carry a pilot or passenger s, the proposed operations can achieve the equivalent level of safety of current o perations by requiring the PIC operating the aircraft to have a private pilot’s li cense rather than a commercial pilot’s license to operate the small UAV. Unlike a conventi onal aircraft that carries the pilot and passengers, Vertical Imagery's UAV is remotely cont rolled with no living thing on board. The area of operation shall be controlled and restr icted, and all flights are planned and
coordinated in advance as set forth in the Vertical Imagery SOP. The level of safety provided by the requirements included in the SOP ex ceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the UAV is s o diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of this UAV as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.1 13(a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthin ess certificate issued for the aircraft, should Vertical Imagery's exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the small size and simplicity of the aircraft and the requirements contained in the SOP and Maintenance M anual for maintenance and use of preflight check lists prior to each flight, an e quivalent level of safety will be provided.

14 C.F.R. §91.121 Altimeter settings. The regulation requires each person operating an a ircraft to maintain cruising altitude by reference to an altimeter that is set “ ...to the elevation of the departurePage 9

Vertical Imagery LLC Section 333 Petition airport or an appropriate altimeter setting availab le before departure.” As the UAS does not have a barometric altimeter, but instead a GPS height AGL read out and a sonic ground proximity sensor, an exemption may be needed . An equivalent level of safety will be achieved by way of the UAS recording its po sition as zero feet AGL upon powering on, and during flight the height AGL is di splayed in real time to the PIC's display. The UH is also equipped with a sonic groun d proximity sensor which detects height AGL and automatically corrects the flight al titude to help prevent inadvertent flight
into terrain.

14 C.F.R. § 91.151(b): Fuel requirements for flight in VFR conditions. Section 91.151(b) prohibits an individual from beg inning “a flight in a rotorcraft under VFR conditions unless (considering wind and f orecast weather conditions) there is enough fuel to fly to the first point of intende d landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.” The batteries powering the Inspire 1 provide approximately 18 minutes of powered flight, therefore meeting the 20 minute reserve requirement is not possible. Vertical Image ry believes that an equivalent level of safety can be achieved by limiting flights to 25% o f remaining battery power. The UAS is also equipped with an audio warning which is set to notify the pilot at a predetermined battery level remaining. If the battery drops below this level, the UH will automatically return home and land, preventing the UH from being in the air when the battery reaches critically low levels. Vertical Imagery's 25% restr iction and the UAS's automated systems would be more than adequate to return the U H to its planned landing zone from anywhere in their limited operating area.

14 C.F.R. §91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections. Given that these sections and Part 43 apply only t o aircraft with an airworthiness certificate, these sections will not apply to Verti cal Imagery. Maintenance will be accomplished by Vertical Imagery pursuant to the SO P, User Manual, and Maintenance Manual. An equivalent level of safety will be achie ved because the UAS will still receive both scheduled and preventative maintenance. As pro vided in the SOP, Vertical Imagery will ensure that the Inspire 1 is in workin g order prior to initiating flight, performPage 10

Vertical Imagery LLC Section 333 Petition required maintenance, and keep a log of any mainten ance performed. Moreover, the operator is the person most familiar with the aircr aft and best suited to maintain the aircraft in an airworthy condition to provide the e quivalent level of safety.

REASONS WHY GRANTING VERTICAL IMAGERY'S REQUEST WOU LD BE IN THE PUBLIC INTEREST Granting the present petition will further the pub lic interest by allowing Vertical Imagery to safely, efficiently, and economically as sist its sister company in performing aerial inspection services of power transmission to wers, lines and other public utilities, along with conducting aerial surveys, electronic ne ws gathering, wildland fire perimeter patrols, and aiding is search & rescue operations. Use of the Vertical Imagery UH for public utilitie s will increase worker safety by reducing human exposure to climbing towers and redu ce the need to fly manned helicopters close to transmission towers for inspec tion purposes. This will also reduce the amount of time required to perform both routine and emergency inspections of the
utilities. Conducting aerial surveys with the UH will reduce the need to fly biologists low and slow over sometimes heavily forested areas in o rder to take accurate counts. This will also greatly reduce harassment to wildlife due to the UH having a much smaller, almost imperceptible, noise signature. Smaller news stations often don't have the budget to pay full sized helicopters to perform aerial work. Utilizing Vertical Imagery's U AS will allow local stations to better gather information and provide the public with more timely and accurate news. Vertical Imagery works in conjunction with many fi re agencies including local, state, and federal who are very interested in the b enefits of a UAS to provide better understandings of wildland fire perimeter condition s. This can greatly benefit fire agencies by allowing them to quickly get aerial vie ws of the fire, allowing them to make faster, more informed decisions. Vertical Imagery also works with several public ag encies conducting search and rescue operations. These operations can be enhanced with a UAS by allowing an "eye in the sky" to quickly and efficiently aid in searc hes.Page 11

Vertical Imagery LLC Section 333 Petition FLIGHT OPERATIONS Operations will only be conducted in the continent al United States. As stated in Vertical Imagery's SOP, proposed areas of aerial op erations include areas that are: 1. Not over congested areas or near large gathering s of people. 2. Not within 5 miles of any airport without airpor t manager's permission. 3. Not within 100 yards of persons or property non- essential to the mission. 5. UH will remain within visual line of sight of th e PIC and VO. 6. No flight above 400 feet AGL. 14 C.F.R. §1.1 defines rotorcraft as "a heavier-than-air aircraft that depends principally on its support in flight on the lift ge nerated by one or more rotors." It also
defines helicopter

as "a rotorcraft that, for its horizontal motion, depends principally on its engine driven rotors." The Inspire 1 meets thes e criteria and therefore should not require a waiver to operate under §91.119 since it can fulfill the requirements of §91.119(d). However, Vertical Imagery will take an added level of safety and not operate over any congested area in addition to oper ating with extra requirements as per its SOP. Vertical Imagery will operate its UAV by regulatio ns such as the ICAO (International Civil Aviation Organization) and the FAA’s own national airspace regulations. In order to increase flight safety and prevent accidental flights in restricted areas, thorough preflight action will be taken to e nsure no airspace violations will occur. As stated in the SOP, extra measures will also be t aken to ensure operations are always conducted in class G airspace in day VMC wit h 3 miles visibility. Vertical Imagery's customers often require flights to occur with as little as 2-3 hours notice, therefore a requirement to obtain a NOTAM prior to each flight will greatly hinder the ability of Vertical Imagery to fulfill its customer s' needs. These are jobs which are normally performed by Vertical Imagery's sister com pany with a manned helicopter, and being able to do these missions with an unmanned he licopter will not only provide an equivalent level of safety, but introduce an added level of safety and service to Vertical Imagery's customers.Page 12

Vertical Imagery LLC Section 333 Petition FLIGHT OPERATIONS OF VERTICAL IMAGERY'S UAV IS LIMI TED TO LINE OF

SIGHT OF THE PIC WITH A VISUAL OBSERVER Vertical Imagery will only utilize PIC’s with a va lid Private Pilot rating certificate issued by the FAA for operation of the UAS and a va lid Class II Medical Certificate along with extensive company training as listed in the SOP. Additionally, all pilots will be assisted by a Visual Observer. The PIC and VO must meet the requirements as set forth by the SOP which include training, briefings, and remaining within voice communication range throughout the flight. Both the VO and PIC will remain within line of sight of the UH during the operation.

OPERATION OF VERTICAL IMAGERY’S UAV WILL BE CONDUCT ED PURSUANT

TO THE STANDARD OPERATING PROCEDURES MANUAL Vertical Imagery's SOP will control operation of t he UAS and will significantly contribute to maintaining the level of safety conte mplated by the airworthiness certificate requirements from which Vertical Imagery now seeks relief. Pursuant to the Maintenance Manual, User Manual, SOP, and 14 C.F.R. § 43.13, entitled Performance Rules (general), each person performing maintenance , alteration, or preventive maintenance on Vertical Imagery's UH, motors, rotor s, hardware, guidance systems or appliances shall use the methods, techniques, and p ractices prescribed in the current
manufacturer's Maintenance Manual or Instructions f or Continued Airworthiness prepared by its manufacturer, or other methods, tec hniques, and practices acceptable to the Administrator. Each person shall use the too ls, equipment, and test apparatus necessary to assure completion of the work in accor dance with accmkojnnk;epted industry practices. A copy of the SOP, Maintenance Manual, and Flight Record & Maintenance Log which is proprietary information to Vertical Imagery, is attached hereto as Exhibit B, and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)Page 13

Vertical Imagery LLC Section 333 Petition CONCLUSION Satisfaction of the criteria provided in Section 33 3 of the Reform Act of 2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security – provide more than adequate justification for the grant of the requested exempt ions allowing commercial operation of applicant’s UAS pursuant to the manual's appended h ereto.

_____________________________ Submitted on April 13, 2015 Ryan P. Corey Vertical Imagery LLC
P.O. Box 1345
2275 Dead Indian Memorial Road Ashland, OR 97520 (541) 488-2880 ryan@timberlandhelicopters.com