U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590

September 1O, 2015

Petitioner Ariel Saint Hilaire 903 Lake Lily Dr. #A111 Maitland, Florida 32751 407-300-4316 www.Flashismyname.com
Ariel Saint Hilaire will be providing clients with high quality imaging for a variety of commercial, public, and residential uses. He is a 8 year experienced Aerial Photographer/Videographer with hours of flying experience and is seeking an exemption from these specific requirements of Title 14 C.F.R.:
1. 91.119(b) and (c) 2. 91.121 3. 91.151(a) 4. 91.405(a) 5. 91.407(a)(1) 6. 91.409(a)(1) and (2) 7. 91.417(a) and (b)

### Definitions
1. AGL Above Ground Level
2. ATC Air Traffic Control
3. COA Certificate of Authorization
4. FAA Federal Aviation Administration
5. FAR Federal Aviation Regulation
6. GPS Global Positioning System
7. NAS National Airspace System
8. PIC Pilot in Command
9. UA Unmanned Aircraft
10. sUAS Small Unmanned Aerial System
11. VFR Visual Flight Rules
12. VLOS Visual Line of Site



### Summary In the instance of granting exemption, Ariel Saint Hilaire will be operating the sUAS in order to fulfill contracted obligations, such as: aerial photography and videography for real estate agents, appraisers, property managers, general contractors; solar panel installation technicians; agriculturists; law enforcement; utility inspections (only where safe flight is attainable); chambers of commerce and associated businesses; wildlife conservation organizations; public departments; all other institution requiring filmography (safe flight permitting)

## Aircraft

DJI Inspire 1 A. Weight (Including Battery and Propellers) 6.47 lbs B. Diagonal Size (Including Propellers) 22.87 in C. Max Ascent Speed 11.2 mph D. Max Descent Speed 9 mph E. Max Flight Time ~ 18 minutes F. Remote Controller Operating Frequency 2.400 GHz 2.483 GHz 5.725 GHz 5.825 GHz
G. AutoTakeoff Rises to a preset height and will hover in place until directed where to go
H. AutoReturn Home Remembers the exact spot it took off from to enable a tap of a button to return back home I. Low Battery Failsafe If the flight battery is run running low or the Inspire 1 loses connection with the remote it will automatically return back home

### Specific Sections of C.F.R From Which Ariel Saint Hilaire Seeks Exemption

1. Section 91.119 Minimum Safe Altitudes Section 91.119 states persons may operate a helicopter at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA. The sUAS meets this criteria as a helicopter and requests the ability to operate at altitudes up to 400’ AGL. Only in accordance with pre obtained consent will the sUAS operate while also maintaining an altitude less than 400’ AGL. For comparison with traditional aircraft and rotorcraft the sUAS weighs less than 10lbs, while also preventing potential risks associated with flammable fuel. Lastly the 400’ AGL ceiling limits any ability for the sUAS to interfere with conventional aircraft operating at or above 500’ AGL. 2. Section 91.121 Altimeter Settings Section 91.121 states each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating below 18,000 feet MSL, to the current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft. In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. The sUAS will reference its altitude based on GPS and will be restricted to a 400’ AGL ceiling. The PIC will also verify GPS elevation from multiple ground based sources prior to takeoff. 3. Section 91.151 Fuel Requirements for Flight in VFR conditions Section 91.151 states no person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. The sUAS battery powered operational flight time is not able to incorporate a 20 minute reserve window following successful first point of intended landing due to current battery capacity limitations. In order to provide adequate reserve power for return landing the sUAS will abide by a 12 minute flight time or 25% of remaining battery power, whichever happens first.
4. Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b) These sections only apply to aircraft with an airworthiness certificate, Ariel Saint Hilaire requests exemption from these sections because the DJI inspire 1 does not require airworthiness certificates. This sUAS is in accordance with FMRA Section 333 for operation, absent an airworthiness certificate. In order to insure proper maintenance the operations manual will be cited for necessary corrective measures. In addition, the PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition, and any sUAS conducted maintenance will be documented for the life of the aircrafts.

### Public Interest

• Real estate agents will be able to set their listings apart with a unique perspective only available from sUAS photographic equipment, therefore increasing the prospect of meeting or exceeding the asking price.

• Property managers and contractors will have the ability to survey their property for anomalies while preventing human endangerment due ? ? to hazardous conditions.

• Solar panel technicians can safely inspect potential installation locations without putting themselves in high elevation and sloping circumstances.

• Agriculturists will have the ability to survey their land in a more timely manner and better document the condition of their property.

• Marketing firms and other businesses would use unique aerial photography and panographic video to promote marketing campaigns and increase revenue.

• Search and rescue entities could utilize the sUAS to help quickly aid in finding the location of person(s) while providing a better vantage point in closer quarters.



### • Public Safety

• The DJI Inspire 1 will reduce air and noise pollution do to the aircraft being powered by a battery and brushless electric motors.

• This small aircraft create less potential for harm, should an emergency situation occur, thanks to their size and weight.

• Furthermore the lack of combustible fuel also significantly decreases their chances of producing harm.

### Conclusion Based on the criteria provided under the FMRA Section 333, Ariel Saint Hilaire requests that the FAA grants him exemption from 14 C.F.R Sections 91.119(b) and (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) in order to conduct contracted commercial sUAS operations using the DJI Inspire 1 for a wide range of industries and applications.

Kind Regards,

Ariel Saint Hilaire