10/02/2015

Just Homes Photography, LLC.

Richard W. Ross

115 High Bluff Road

Hilton Head Island, South Carolina 29926

1-844-376-6328 phone

1-843-682-2462 fax

Rick@JustHomesPhotography.com

US Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington DC 20590

RE: Exemption Request Section 333 the FAA Reform Act of 2012

Attachments:

1) Copy of Airline Transport Pilot Certificate

2) Copy of current First Class Medical Certificate

3) DJI Phantom 3 Professional User Manual V1.0 2015/04

4) DJI Inspire I User Manual

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0418 in the matter of

the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0S08 in the matter of

the petition of ADVANCED AVIATION SOLUTIONS, LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-03SS in the matter of

the petition of FLYING CAM INC
Dear Sir or Madam,

In accordance with the FAA's Guidelines for Submitting Petition for Exemption under 

Section 333 of the FAA Modernization and Reform actof2012, I Richard W, Ross, owner 

and operator of Just Homes Photography, LLC referred to hereafter as the petitioner, 

request exemption to 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) 91.407(a){1); 

91.409(a)(1); 91.409(a)(2);

91.417(a)&(b)

In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of Aerial 

Photography, Cinematography, Videography, Inspections and other flight operations that 

could be performed safely and more cost effectively with the use of small UAS at low 

altitude within the US National Airspace System as compared to a manned aircraft. 

Operations will only be performed at the request of and with the authorization and 

consent of clients and their authorized agents in order to facilitate commerce and raise 

awareness of beneficial uses of small UAS. So long as such operations are conducted 

within and under the conditions outlined herein or 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

The petitioner seeks the exemption from the above mentioned FARs for the following 

reasons:

61.113(a) & (b): The petitioner requests relief in order to facilitate utilization of pilots 

who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this 

exemption would be required to comply with any conditions as set forth and in a similar 

fashion as the previously granted exemptions.

91.119(c) As discussed in Exemption 11139 (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 of "congested areas" and "densely populated." The petitioner requests waiver 

for this condition to allow reasonable and responsible operations in areas of subdivisions 

and neighborhoods.
91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU), this is inapplicable 

since the UAS does not have an altimeter and instead utilizes 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 aircraft to operate at less than prescribed 

minimums including Exemption NO.s 2689, 5745, and 10650. In addition similar UAS 

specific relief has been granted an Exemption No.s 8811, 1080, and 10673 for daytime, 

VFR operations. The UAS provides battery power remaining in percent to the PIC. The 

UA batteries provide approximately 25 minutes of powered flight. Information provided 

in the operating documents discusses procedures regarding remaining battery power 

management. The documents contain a condition in which the PIC will initiate a landing 

procedure when the 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 daytime VFR conditions was reasonable.

91.405(a); 91.407(a); 91.409(a) (1) & (2); 91.417(a) & (b) As discussed in Exemption 

11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure the UAS 

is in a condition for safe flight in accordance with the operating documents. The FAA 

found that adherence to the petitioners operating documents and the conditions and 

limitations specified, describing the requirements for maintenance, inspection and record 

keeping, were sufficient to ensure that safety would not be adversely affected.

The UAS

The DJ I Phantom 3 Professional and the DJI Inspire 1 are highly successful consumer 

grade small rotorcraft in the quadcopter configuration with an advertised weight of less 

than 106 Ounces (3000g) designed primarily to carry a high definition camera aloft. They

have an advertised maximum speed of less than 43 kts (22 m/s) and a maximum climb 

rate of less than 1200 fpm (6 m/s), They are powered by 4 electric motors with a distance 

between the motors of less than 18 inches (457 mm). It utilizes an internal inertial 

measuring unit (IMU) with integrated barometric sensor to augmented with Global 

Positioning System (GPS) to maintain its geospatial orientation and position. It is 

controlled primarily through an FCC certified radio control (Re) unit. Real time video 

and telemetry information is transmitted back to a ground control station allowing the 

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), 

distance from the PIC, camera imagery, and control camera angle. It has failsafe modes 

of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard 

flight controller and maximum altitude can be preprogrammed by the PIC. Battery life 

limits flight times to approximately 25 minutes. The onboard flight controller will warn 

the pilot via telemetry data and external lighting cues before reaching a low battery state. 

An automatic termination of flight and landing will be initiated when battery reaches a 

predetermined low state. It is anticipated that flights will usually last less than 15 

minutes. More information is available in attachment 3 and 4.
Risk Mitigation

The petitioner has reviewed FAA exemptions references 1-3 Conditions and Limitations 

section and believes that the procedures specified therein are reasonable and will be 

utilized in order to manage and mitigate risk and ensure public safety. A preflight and 

post flight checklist will be developed and employed to ensure that UA airworthiness will 

be maintained for flight operations. Flight time and maintenance logs will be maintained 

to ensure tracking on failure prone components. The petitioner requests that in a manner 

similar to reference 3, he be allows to operate within 5 miles of an airport provided that:

"The UAS may not operate in Class 8, CorD airspace without written approval of the 

FAA The UAS may not operate within five nautical miles of the geographic center of a 

nontowered airport as denoted on o 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 NO TAM as required by the operator's GOA 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 requesting a mechanism to facilitate such activities without requesting a new and 

separate exemption should the need arise. Operations within class B airspace are not 

requested due to the lack of a mode C transponder.

Public Interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce 

environmental impact compared to similar operations conducted with much larger fuel 

laden manned aircraft Additionally, the use of UAS to facilitate commerce can help to 

encourage economic growth. Operations for this petition will enable service for property 

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 photography is a valuable marketing tool 

that can facilitate increased commerce and enhance personal photography. Crop 

surveying and inspections could lead to decreased use of pesticides and fertilizer and 

conservation of water as well as increased crop yields and decreased costs. Aerial 

surveying and inspections can increase work site efficiency, improve volumetric 

estimations and reduce risk. The petitioner will provide clients with the photographic data 

for these purposes in a for hire basis acting as an independent contractor. A visual 

observer will be utilized. Flight data including UA flight time, Control unit operation 

time, incident, accident, and details concerning any deviations from normal operations 

will be available to the FAA for use in collecting data regarding the use of UAS as a part 

of this application. This data can be submitted to the FAA via reports as required by the 

FAA.
Conclusion

The petitioner is requesting this exemption for the purposes of "aerial photography, 

cinematography, videography, mapping, inspections and other flight operations." The 

reason for such a general and broad based request is that the petitioner wishes to utilize a 

strategy that allows maximum flexibility to utilize the UA to its fullest potential within 

the constraints of this request, without the long turnaround time associated with 

additional exemptions. The petitioner plans to offer services to individuals or companies 

seeking to enhance their business in a safe and lawful way. The petitioner knows that 

there is extensive demand for lawful aerial photography and videography. The petitioner 

has over 10,000 hours flying experience, and 37 years of experience flying radio control 

airplanes and helicopters. The petitioner holds an Airline Transport Pilot Certificate 

(multi-engine engine land) (see attachment 1), and a current first class medical certificate 

(see attachment 2). The petitioner plans to utilize the UAV below 400' AGL, within 

visual line of sight (VLOS), within 500' laterally of the PIC, and with a visual observer at 

all times.

If the petitioner requires additional pilots in the future, it will attempt to employ those 

whose qualifications meet or exceed the principles. At a minimum, all pilots operating 

under the petitioners exemption will, at a minimum, have a sport pilot license, along with 

a valid drivers license, and experience operating an UAV less than 55 pounds including 

payload.

Thank you for your consideration,

Richard W. Ross

Owner / Operator

Just Homes Photography, LLC.

1-844-DRONE2U