November 3 rd 2015

Maxwell Palmer 15538 E. Melanie Dr. Scottsdale, AZ 85262 602

- 430

- 7457 palmer_max@yahoo.com U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey Ave SE Washington, DC 2059 RE: Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments:

1. 1) DJ I Phantom 2+ User Manual as downloaded HERE (file size too large to attach) References:

1. 1) FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the petition of DOUGLAS TRUDEAU 2. 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

–2014

– 0508 in the matter of the petition of ADVANCED AVIAT IO N SOLUT IONS LLC 3. 3) FAA Exemption No. 11080 Regulatory Docket No. FAA

- 2014

- 0355 in the matter of the petition of FLYING CAM INC Dear Sir or Madam, In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, Maxwell Palmer , referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations: 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.4 07(a)(1); 91.409 (a)(1); 91.409(a)(2); 91.417(a) & (b); In order to operate small unmanned aircraft s ys tems (UAS) commercially in airspace regulated b y the Federal Aviation Administration (FAA) for the purposes of aerial photograph y of primaril y the petit ioner ’ s real estate listings. Operations will be performed onl y at the request of and with the authorization and permission of clients or their authorized agents in order to better highlight homes for sale via aerial photography

. So long as such operations are conducted within and under the conditions outlined hereinor as may be established by

the FAA as required by

Section 333. The conditions identified and proposed by the petitioner are drawn from references 1

- 3.

**The FARs** Th e petitioner seeks exemption from the above

- mentioned FARs for the following reasons; 61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. An y pilots operating under this exemption would be required to compl y with any conditions as set forth and in a similar fashion to the previously granted exemptions. 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “conges ted areas” and “densely populated”. The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required. 91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inappl icable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned air craft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for day time, VFR conditions. The UAS provides battery power remaining in percent to the PI C. The UA batteries provide approximately 25 minutes of powered flight. In formation provided in the operating documents discusses procedures regarding remaining battery

power management. Those documents contain a conditi on in which the PI C will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, the FAA found that a reduced minimum power reserve for flight in day time VFR conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in ac cordance with the operating documents. The FAA found that adherence to the petitioner’s operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and record keeping, were sufficient to ensure that safet y would not be adversely affected.**The UAS** The petitioner plans on utilizing the DJ I Phantom 2+. Th is a irframe is a "pro

- sumer" grade small rotorcraft in the quadcopter configuration powered b y electric motors. Individual Specifications for the airframe is located in the table below. This airframe utilize s an internal inertial measuring unit (IMU) global positioning s ys tem (GPS) to maintain its geospatial orientation and position. It is controlled primarily thr ough an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PI C to monitor battery

level, GPS signal strength, altitude (AGL), distance from PI C, came ra imagery , and control camera angle. Failsafe modes of operation for either loss of signal (RC or GPS) or battery level. Altitude is limited and pre

- programmed to not exceed 400ft AGL. Battery life limits flight times to approximately 20

- 25 minutes for e ach airframe. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery

state. An automatic termination of flight and landing will be initiated when the battery

reaches a predetermined low stat e. It is anticipated that flights will usually last less than 10 minutes. More information is available in product manual , which is attached. UAS Airframe Specifications

DJI Phantom 2+ Weight (Pounds) Approx 3lbs Dimensions (inches) 19”X19”X8” Max Speed (Knots) 30

**Risk Mitigation** The petitioner has reviewed FAA exemptions reference’s 1

- 3 Conditions and L imitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safet y. A preflight checklist has been developed and emplo yed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight

. The petitioner requests that in a manner similar to reference 3, he be allowed to operate within 5 miles of an airport provided that;“The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may

not operat e within 5 nautical miles of the geographic center of a non

towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.” Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requ esting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within Class B airspace are not requested due to the lack of Mode C transponder.
**Public Interest** Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionall y, use of the UAS i n order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for propert y owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography /photography . Aerial photograph y is a valuable marketing tool that can lead to increased commerce and enhance personal photograph y. The petitioner will provide clients with photographic dat a for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized.
**Conclusion** The petitioner is requesting this exemption for the purposes of “aerial photograph y, cinematograph y, and videograph y . There is demand for this service within the real estate industry and more specifically

the luxury

real estate market. The petitioner is uniquely suited for such operations being a licensed pilot as well as a real estate agent and would like to be able to take adv antage of the above skillset in a legal manner. Adding to the level of safety and experience in these operations, the petitioner has 5 ye ars of experience in the radio control model aircraft hobby , 17 ye ars experience in general and commercial aviation and holds the following FAA Licenses and Ratings: Airline Transport Pilot Certificate (AMEL) Commercial Pilot L icense (ASEL ) Certified Flight Instructor

- Single and Multi Engine Land, Instrument Airplane Thank you in advance for your time and consideration. Kind Regards,Maxwell Palmer