10/02/2015

Just Homes Photograph y, LLC. Richard W. Ross 115 High Bluff Road Hilton Head Island, South Carolina 29926
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US Department of Transportation Docket Management Sy stem 120 0 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) DJIPhantom 3 Professional User Manual V 1.0 2015/04 4) DJIInspire 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 p etition of ADVANCED AVIATION SOLUTIONS, LL C 3) FAA Exemption No. 11080 Regulatory Docket No. FAA

- 2014

- 03SS in the matter of the petition of FLYING CAM I NCDear Sir or Madam,

In accordance with the FAA's Guidelines for Submitting Petition for Exempt ion under Section 333 of the FAA Modernization and Reform actof2012, I Richard W, Ross, owner and operator of Just Homes Photograph y, LLC referred to hereafter as the petitioner, request exemption to the following sections of Title 14, Code of Federal Regu lations: **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 s ys tems (UAS) commercially in airspace regulated b y the Federal Aviation Administration (FAA) for the purposes of Aerial Photograph y, Cinematograph y, Videograph y, 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 S ys te m 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 lo ng as such operations are conducted within and under the conditions outlined herein or as may be established b y the FAA as required b y section 333. The conditions identified and proposed b y the petitioner are drawn from references 1

- 3.
**The FARs** The petit ioner 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 an y 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 ar eas" and "densel y 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 les s 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 day time, VFR operations. The UAS provides battery power remaining in percent to the PI C. 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 PI C will initiat e 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 day time 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 document s. 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 safet y would not be adversely af fected.

**The UAS** The DJ IPhantom 3 Professional and the DJ I Inspire 1 are highl y successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 106 Ounces (3000g) designed primaril y to carry a high defi nition 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 uti lizes an internal inertial measuring unit (IMU) with integrated barometric sensor to augmented with Global Positioning Sy stem (GPS) to maintain its geospatial orientation and position. It is controlled primaril y 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 PI C 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 b y the PIC. Battery life limits flight times to approximately 25 minutes. The onboar d 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 th at 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 speci fied therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safet y. A preflight and post flight checklist will be developed and employed to ensure that UA airworthiness will be maintained for flight operations. F light 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 t hat 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 w ithin 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 requ ested 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 Additional ly , the use of UAS to facilitate commerce can help to encourage 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 d esired photographic subjects that cannot be display ed through ground level videography /photography . Aerial photograph y is a valuable marketing tool that can facilitate increased commerce and enhance personal photograph y. Crop surveying and inspections coul d lead to decreased use of pesticides and fertilizer and conservation of water as well as increased crop yi elds and decreased costs. Aerial surveying and inspections can increase work site efficiency , improve volumetric estimations and reduce risk. The pet itioner 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.**Conclu sion** 

The petitioner is requesting this exemption for the purposes of "aerial photograph y, cinematograph y, videography , mapping, inspections and other flight operations." The reason for such a general and broad based request is that the petitioner wishes t o 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 indivi duals or companies seeking to enhance their business in a safe and lawful way . The petitioner knows that there is extensive demand for lawful aerial photograph y and videograph y. The petitioner has over 10,000 hours flying experience, and 37 years of experi ence 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 utiliz e the UAV below 400' AGL, within visual line of sight (VLOS), within 500' laterally of the PI C, 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 y our consideration,

Richard W. Ross Owner / Operator Just Homes Photograph y, LLC. 1

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