Petition for Exemption/Rulemaking 14 CFR § 11.81 under “section 333.”

 Attn: Public Docket ( NO.FAA-2015-1562 )

I am a Navy veteran with over 9 years of experience as an airframes and power plant mechanic. I’m also 

a student trainee pilot with over 80 hours of flight time who’s awaiting his check ride. I currently hold a 

third class medical certificate that is up to date. My passion for aviation and aeronautics goes further 

back than I can remember. I have close to five years of RC flight time as I build model aircraft for a 

hobby, as well as 100hrs of drone flight time.my passion for aviation led me to pursuit a MA in 

aeronautics at Embry Riddle Aeronautical University. I am in my first year there. Furthermore; I am part 

owner in a video production and cinematography company based out of San Diego, CA. And as an 

expansion to our existing list of services, we wish to provide real-estate based drone footages for 

prospective buyers and sellers in the market looking to buy and/or sell commercial and residential 

properties.

Petioner’s Request

The petitioner’s Request is to operate an unmanned aircraft system (UAS) to conduct aerial photography 

and videography for real-estate, land surveying, agriculture, forestry, wildlife preservation, events, and 

cinematography

Training to persons (individually, or belonging to both private and/or public organizations)

Why the request is needed

The ability to supply aerial footage over the large agricultural terrain of the Santa Fe area/ Fallbrook and 

Santee area ( to name a few) would greatly benefit farmers, residents and real estate’s agent alike.

Currently such footages are dependent on aircraft’s that mostly does not have the capability to fly at 

low altitudes. And not to mention; the cost for such venture is expensive and it does not benefit the 

public’s best interest. We were also approach by a local fire Dept to lend a hand in the times of fire 

seasons to help with to lower the cost of operations.

Relief Request

(b) The specific section or sections of 14 CFR from which you seek an exemption;

14 CFR part21, Certification procedures for products and parts, Subpart H Airworthiness Certificates

Part 61 Certification: Pilots, Light Instructors, and Ground Instructors

(c) The extent of relief you seek, and the reason you seek the relief;

 5 years

(d) The reasons why granting your request would be in the public interest; that is, how it would 

benefit the public as a whole;
Granting this request will help our community to take advantage of a new technology that can 

saves time in agriculture inspections, improves buyers guide to the local real-estate market with 

improved imagery and cinematography. Approving this request will assure the public we are in 

compliance of the government and local laws that governs us. the need for a faster way to obtain 

topography is long overdue in the construction industry. Our local community can benefit greatly 

with the help of our new technology.

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from which 

you seek the exemption;

Granting this exemption will NOT adversely affect safety. In fact we plan to exemplify a model for how 

to operate UAS safely within the National Airspace System. I have spent some time studying U.S 

National Airspace as part of my General aviation private pilot certification. I understand the do’s and 

Don’ts of this unique environment. Any person whom will operate UAS under my company’s name” 

Eaglelens Photography” will have attend a UAS safety course with a certification of completion to prove. 

Safety is the reason why the U.S National Airspace is the safest airspace in the world. We intend to 

continue to uphold the safety operation that makes us number one. To achieve that, we will not tolerate 

any shortcut when it comes to safely operating our UAS. We will train on its operational capabilities, 

Limitations, safety features, parts, and aerodynamics stabilities. Proper pre-flight and post-flight is 

conducted before and after flight. Also a log is maintained for all UAS to document every flight to help 

improve safety. Lastly granting us this exemption will enable us to serve the communities from which 

we reside and build relationships with.

 Currently, section 333 limits operation to 400ft AGL but will allow up to 500ft AGL if the PIC has a 

visual line of site of the UAS. I also understand that this section also prohibits operations closer than 500 

ft from any persons, vehicle, vessel or structure not in involved in the UAS operation, except with the 

full consent of the landowner(s) and the PIC (Pilot in command) conducts a thorough risk assessment. 

Although not stated in the current section 333 exemptions; I know to remain clear of class B,C and D 

airspace without first obtaining ATC Clearance/permission. And I am fully aware that the Exemption 

clearly prohibits UAS operations to be conducted closer than 5 miles of any Airport reference point as 

noted on a current published aeronautical chart.

I will be operating a Dji Inspire 1. And we will be able to comply with 14 CFR part 91 “general operating 

and Flight rules. As a PIC I understand the need to be knowledgeable/ trained with manufactures 

operator training policy. And to follow instructions set forth by the company (Dji) that will lead to safe 

flight by completing a thorough pre-flight prior to each flight. Guidelines for pre-flight are included in 

the operator’s manual. As a policy, my company operates a two men crew to allow for observer in all 

aspect/phases of the flight. Maintenance and repair of the Dji inspire shall/will be conducted in 

accordance to manufacturer recommendation as described in the Dji owner’s operating manual. 

Below is some of the features/specification that accompanies the dji Inspire 1. I believe that they 

embody safety and efficiency under one airframe system.
Features:

 A beautiful, 720p HD view shows you exactly what your camera sees at all times. Frame your 

shots and fly as though you're in the sky yourself.

This is made possible by an all new and improved version of DJI's Lightbridge technology which 

can transmit video from up to 2km away.

 Dual remote option to aid in safety and efficiency.

With two operators controlling the same Inspire 1, one person pilots the flight path while the other aims 

the gimbal and camera. Each user can have their own screen to see exactly what is being shot in realtime.

 Intelligent power management system (Battery)

A fully integrated intelligent battery powers your Inspire 1 and virtually manages itself. 

When in flight, your remaining battery power is shown live, letting you know how long you can continue 

to fly. Advanced algorithms calculate the distance of your aircraft and estimated time to return home, 

letting you know when it’s time to fly back.

The battery reports the voltage of each cell, the total lifetime charges and discharges, and the overall 

health and battery status.

 The “Home” point system.

When GPS is available, the Home Point (the location you are standing) automatically refreshes, so your 

Inspire 1 always knows where you are even if you move around. When you tell it to come back, or in 

case of an emergency, it knows exactly where to go and land safely.

 Camera and Gimbal system

• Video: 4K @ 24-30 fps, or 1080p @ 24-60fps,

• Photos: 12 Megapixels

• Lens: 9 elements in 9 groups including an aspherical element

• 1/2.3 inch CMOS sensor• 940 wide-angle FOV

• 3-axis, 3600 rotating gimbal
Specifics:

Aircraft :

 Model T600

 Weight (Battery Included) 2935 g

 Hovering Accuracy (GPS mode) Vertical: 0.5 m

 Horizontal: 2.5 m

 Max Angular Velocity Pitch: 300°/s

 Yaw: 150°/s

 Max Tilt Angle 35°

 Max Ascent Speed 5 m/s

 Max Descent Speed 4 m/s

 Max Speed 22 m/s (ATTI mode, no wind)

 Max Flight Altitude 4500 m

 Max Wind Speed Resistance 10 m/s

 Max Flight Time Approximately 18 minutes

 Motor Model DJI 3510

 Propeller Model DJI 1345

 Operating Temperature Range -10° to 40° C

 Diagonal Distance 559 to 581 mm

 Dimensions 438x451x301 mm

Remote control:
 Operating Frequency 922.7~927.7 MHz (Japan Only)

 5.725~5.825 GHz

2.400~2.483 GHz

 Transmitting Distance (outdoor and unobstructed) 2 km

 EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

 Video Output Port USB, mini-HDMI

 Power Supply Built-in battery