UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Osprey Imaging, LLC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 C.F.R. Part 21

SUBPART H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b); 

91.105; 91.109; 91.119; 91.121; 91.151(a);91.203(a) AND (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) 

(2); 91.409 (a) (2) AND 91.417 (a) & (b) CONCERNING COMMERCIAL OPERATION OF THE DJI 

PHANTOM 2 AND DJI S1000 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted this 19th of May, 2015

William Granruth &

Alexander Pugliese of 

Osprey Imaging, LLC. 

261 Mill Street 

Greenwich, CT 06831

203-249-2342

william@ospreyimaging.com
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William Granruth 

Osprey Imaging, LLC

261 Mill Street

Greenwich, CT 06830

May 19, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from Title 14 C.F.R. Part 21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113( a) and 

(b);91.7 (a); 91.9 (b)(2);91.103(b); 91.105; 91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 

91.405(a); 91.407 (a)(1); 91.409 (a) (2); 91.409 (a)(2) and 91.417 (a) and (b) concerning commercial 

operation of the DJI Phantom 2 and DJI S1000 Unmanned Aircraft Systems ("UAS"). 

To Whom It May Concern:

I am respectfully submitting this request for an exemption from Section 333 of the FAA Reform 

Act of 2012 and Part 11 of the Federal Aviation Regulations from 14 C.F.R 45.23(b); 14 C.F.R. §§ 

61.113( a) and (b); 91.7 (a); 91.9 (b)(2); 91.103(b); 91.105; 91.109; 91.119; 91.121; 91.151(a);

91.203(a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a) (2) and 91.417 (a) and (b) to 

operate the above-identified UAS commercially for buyer education purposes in the real estate 

and marine industries. 

Summary

Our company specializes in luxury marketing and buyer education. The majority of our clients are 

agents and brokers that specialize in serving non-local buyers of yachts and real estate. 

Osprey Imaging, LLC ("Osprey") is a Connecticut limited liability company which is engaged in

property marketing services. Due to the nature of our clients, the majority of buyers targeted in 

our marketing pursuits are long distance. In view of the large investment required for the purchase 

of luxury real estate or vessels, it is of significant value to use an unmanned aerial system for aerial 

photography and videography. Aerial videos and photographs assist potential buyers of property 

in making an informed decision regarding their purchase. Many buyers targeted by Osprey view 

these videos and photos on the internet: the combination of aerial and traditional photography 

assists the buyers in noting the condition of structural elements which otherwise would be out of 

view. 
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Unmanned Aerial Systems

The UAS that Osprey will be using are small rotorcraft weighing less than 55 pounds (25 Kg), at 

maximum payload capacity. The UAS operate at a maximum speed of 30 knots, and are restricted 

to a maximum altitude of 400 feet above ground level ("AGL"). Furthermore, the UAS are

restricted to within 900’ of the sole operator and visual observer ("VO") to ensure unaided visual 

contact at all times by both the VO and the pilot in command ("PIC"). These restrictions, in 

combination with point-of-view video transmission and instrumentation, ensure that Osprey's 

operations would not pose a hazard to the National Aerospace System. Furthermore, an additional 

crew member will confirm that a sterile area is maintained within a 200 ft. radius of the aircraft, in 

order to guarantee that any persons within this radius are willing participants and have been 

briefed on the operation taking place. The particular UAS to be operated by Osprey are identical in 

make and model to aircraft previously granted exemptions, including the DJI Phantom 2 and DJI 

S1000. Both aircraft have return-to-home safety features in the event of lost-link and the DJI 

S1000 has a parachute recovery system which will prevent uncontrolled descent of aircraft in the 

event of catastrophic failure. These safety systems can either be manually initiated by the PIC, or 

automatically initiated in the event that the flight control systems sense a failure. 

Specifications of the DJI Phantom 2 can be found in Appendix A.1

Specifications of the DJI S1000 can be found in Appendix A.2

Specifications of the parachute recovery system can be found in Appendix B

Flight Operation Procedures

Osprey's owners have spent several hundred hours in the cockpit of fixed wing aircraft, and are 

avid aviation enthusiasts. Therefore, we understand the imperative of safety when flying an 

airplane or an UAS. 

The procedures for flight are as follows (in no particular order):

1. With an observer, the PIC will perform a pre-flight walkthrough of the location that is going to 

be filmed or photographed, noting any obstructions which might interfere with safe operation of 

the UAS (trees, power lines, buildings, antenna, etc.).

2. Ensure no obstacles will interfere with line of sight at any point during flight. 

3. Test batteries in UAS, remote controls, and range extenders. No aircraft will take off with less 

than 80% battery power. The UAS will be grounded before the battery level (which is monitored 

remotely via instrumentation and timer) reaches 25%.

4. Conduct a pre-flight checklist: Appendix C. 1 or C.2.

5. Review the plan for the flight with the observer. Review altitudes, distances, and movements of 

the UAS. 

6. Ensure the PIC has required pilot and medical licenses on hand. 
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7. Establish a sterile operation area. Consent will be obtained from any persons in the area, and 

either the PIC or VO will conduct a safety briefing for all consenting participants. The ground 

control crew member will ensure a safety perimeter of 200 feet is maintained at all times around 

the aircraft. 

8. The operator will obtain a certificate of authorization prior to takeoff, with the appropriate 

Flight Standards District Office.

9. If required, the PIC will submit a written plan of activities to the FSDO 3 days prior to the 

operation of an UAS. 

10. PIC and observer will maintain voice communication throughout the entire flight. 

11. Permission from homeowner, landowner, or other property owner will be obtained prior to 

flight.

12. Permission from the local authorities will be obtained prior to flight. 

13. In the event the UAS loses signal, the built in programming will force the UAS to return to its

location of take-off, and will safely land and power down. 

14. Flights have the capability of being aborted due to unpredicted obstacles or emergencies.

15. In the event of emergency and/or uncontrolled decent due to unforeseen situations (bird

strike, motor failure, etc.), the PIC will deploy the parachute system and ground crew will maintain 

site security until the aircraft has been secured and area determined safe. 

Radio Frequency 

The UAS operates at a frequency of 5.728GHz- 5.85 GHz. The UAS are compliant with the FCC to 

800m. The power of the radio falls within the FCC compliance of 100mW. 

Qualifications of UAS PIC

At all times, the PIC of the UAS will be an FAA certified Private or Sport Pilot with a current 3rd 

class medical or U.S. driver’s license. Because the UAS will not carry passengers and will fly within 

a restricted area, it will exceed the safety standards set forth in 14 C.F.R 61.113 A & B. The PIC will 

also undergo training that the FAA will require to operate such UAS. The PIC will have over 100 

hours of flight time logged on the aircraft. The PIC will also carry at all times a portable 2-way radio 

for air traffic monitoring and announcement of the location of the UAS if required by the FAA. At 

all times, there will be an observer who also will monitor the UAS, surrounding buildings and

obstacles, and observers. This observer will be the second set of eyes to warn of any dangers that 

may affect the safe flight of the UAS. The UAS PIC will maintain a log of all flights completed for 

each UAS airframe, and will log all maintenance activity. 

Operations of the Unmanned Aircraft

The flights of the UAS will not pose a safety threat with the proper procedures in place as specified 

in the section "Flight Operation Procedures." As described earlier, at all times, Osprey will have an 

observer, a safety perimeter of 200 feet, battery levels above 80% before flight, a full pre-flight 
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checklist and run-up, review of the flight plan, permission of property owners, written plan 

submitted to the FSDO if required, proper communication between PIC and observer, and 

permission from local authorities. Flight operations will be restricted to daylight hours and VFR 

conditions.

The UAS’ maximum airframe speed is 29 knots and typical operating speeds will be around 3-10 

knots. The UAS will not be operated if clouds are below 700ft AGL. This will ensure a safe distance 

from clouds and any low-flying aircraft.

The UAS will not be used in high-density population settings which might present too many safety 

concerns. Potential hazards in the UAS' intended areas of operation are trees, power lines, 

structures, street lights, and fences. Because of the slow flight of the UAS when in operation for 

videography and photography for the intended purpose, the PIC and observer will be able to safely 

maneuver the UAS around such obstacles. The UAS also have the capability of hovering in place 

which allows the aircraft to be flown at very low speeds. 

The UAS will never be flown near any airport and the altitude of the UAS will barely be higher than 

ground structures. Consequently, the UAS will not pose any safety concern to piloted aircraft in 

the area. However, for added safety, a 2-way radio to communicate to air traffic will always be on 

hand. In addition, the UAS will never be flown within a 6 -mile radius of any large international 

airport. The UAS has built in restrictions that prevent flight within those distances from an airport. 

The built-in flight restrictions prevent takeoff in a 6 -mile radius of a Class B airport. 

If required by the FAA, the local FSDO will be notified of flight operations prior to flight. 

Maintenance 

The UAS will be maintained and inspected every 50 flight hours by a manufacturer-certified 

technician. Any replacement components will be genuine manufacturer replacement parts, and 

installed by manufacturer technician. A log will be kept of all maintenance activities and 

inspections, and will be present at any time of aircraft operation. 

14 C.F.R. Part 21, Subpart H, 91.203(a) and (b): Airworthiness Certificate

Because the UAS is under 55 lbs, fully loaded, and does not carry a pilot, passengers, or any 

flammable fuel, and the UAS operates in a fully-restricted and controlled environment, we request 

exemption from 91.203(a) and (b). 

14 C.F.R. 45.23(b): Marking the Aircraft

The UAS will not have an airworthiness certificate and because there is no entrance to the cabin, 

cockpit, or pilot station, there is no place inside the aircraft to place the word "Experimental." If 

required by the FAA, we will place the word "Experimental" on the exterior of the UAS. However, 

due to the size of the aircraft, 2-inch lettering will not be possible. 

14 C.F.R. 61.113(a) and (b): Private Pilot Privileges and Limitations

Unlike civil aircraft, the UAS does not carry living things on board; rather, it is controlled remotely 

via a safe and restricted location. As risks during operation of the UAS are negligible in comparison 
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to full-scale aircraft, the PIC will exceed the present level of safety required for a commercial pilot 

to operate a rotorcraft with a commercial license.

14 C.F.R. 91.9 (b)(2): Civil Aircraft Flight Manual in the Aircraft

Because of the size and configuration of the UAS, no such manual can be carried. The flight manual 

will be carried at the ground station where the PIC and observer are operating the UAS. 

14 C.F.R. 91.103 (b)(2): Preflight Action

A thorough pre-flight inspection and run-up of the aircraft will be performed prior to any flight of 

the UAS. The pre-flight checklist can be found in Appendix C.1 or C.2.

14 C.F.R. 91.105: Flight Crewmembers at Station

Because there are no persons on board a UAS, Osprey's use of a UAS should be exempt from 

regulation 91.10S. However, "crewmembers" – namely the PIC and observer -- will be on the 

ground and in direct communication at all times. 

14 C.F.R. 91.109: Flight Instruction

The UAS does not have dual controls. The PIC communicates to the UAS via radio control. The FAA 

has approved exemptions for flight training without fully functional dual controls for a number of 

aircraft. 

14 C.F.R. 91.119: Minimum Safe Altitudes 

The UAS will never operate at an altitude greater than 400ft AGL. It will be operated within a 

restricted area and with the consent of any and all persons or property involved. 

14 C.F.R. 91.121: Altimeter Settings

The UAS that will be used do not have altimeters. Rather, the aircraft use GPS to determine the 

altitude. Since the normal protocol is to set the altimeter to the barometric pressure reading at 

the time of flight, an exemption will be needed. A safety check will be performed before each 

flight ensuring that the GPS altitude is reading correctly.

14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions

The battery in the DJI Phantom 2 and DJI S1000 are capable of 25 minutes of powered flight. Given 

that the UAS will never be further than 900ft away and 400ft AGL, the longest possible time it 

could take the UAS to return to the ground safely is approximately 1.5 minutes. The UAS will be 

returned to the landing zone within 15 minutes of takeoff, or so as to ensure a minimum 

remaining battery capacity of 25% upon landing which represents approximately 10 minutes of 

flight time remaining. 

The UAS is programmed to automatically land in a safe and controlled manner upon reaching 10% 

battery capacity. Battery life as well as flight-time remaining is displayed on the screen visible to 

the PIC and observer. For safe flight, the UAS will never be operated with less than 25% of battery 

life. 
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14 C.F.R. 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

The UAS weighs under 55 pounds and does not have an on-board pilot operating it. The UAS is not 

capable of carrying such documents should they be required. These documents, if required by the 

FAA, will be carried by the PIC and will be accessible upon request immediately. 

14 C.F.R. 91.405(a); 407(a)(1); 409(a)(2); 417(a) and (b): Maintenance Inspections 

This regulation applies to aircraft that have an airworthiness certificate and should not apply to 

the operation of my intended use for the UAS. However, regular maintenance, checks, and 

cleaning of the UAS will be performed before each flight and if required by the FAA, will be logged 

into a log book and surrendered upon request. Regular maintenance will include cleaning of the 4 

motors on the UAS Rotorcraft, motor testing, flight control testing, checking lights, and a cleaning 

of the entire UAS. Should a mechanical issue arise during a flight, the UAS will land immediately 

and should not pose a safety concern because of its lightweight, restricted flying area, and low and 

slow maneuvering. Complete inspection and/or overhaul if required will be performed every 100 

flight hours on airframe. All maintenance, inspections, and/or component replacements will be 

conducted by a manufacturer authorized technician. 
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Summary

We believe that Osprey's operation of the aforementioned UAS will meet and exceed all current 

safety standards established by the FAA.

Osprey is seeking exemption from the following rules: 

14 C.F.R. Part 21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b); 91.7(a); 91.9(b) (2);

91.103(b); 91.105; 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407(a) (1); 

91.409 (a)(2); 91.409 (a)(2) and 91.417 (a) and (b) to operate commercially for buyer education 

purposes.

Approval of this exemption will ensure safe flight operations for Osprey's UAS following the strict 

guidelines set forth in this request.

Should you need to reach us for comments or questions, our correspondence information is: 

William Granruth

Osprey Imaging, LLC.

261 Mill Street 

Greenwich, CT 06831

203-249-2342

william@ospreyimaging.com

Osprey respectfully submits the aforementioned criteria for exemption in Section 333 of the 

Reform Act of 2012 (specifically size, weight, speed, operational capabilities, proximity to airports, 

populated areas, operation within visual line of sight, and national security considerations) have 

been fully satisfied and justification has been provided for this exemption. 

Thank you for your consideration.

Respectfully, 

William Granruth

President

Osprey Imaging, LLC. 
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Appendix A

Section 1. – DJI Phantom 2 Specifications

Aircraft

Operating environment temperature -10°C to 50°C

Power consumption 5.6W

Supported Battery DJI Intelligent battery

Weight (including the battery) 1000g

Take-off Weight ≤1300g

Hovering Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s

Max Flight Speed 15m/s (Not Recommended)

Wheelbase 350mm

2.4GHz Remote Controller

Operating Frequency 2.4GHz ISM

Communication Distance (open area) 1000m

Receiver Sensitivity (1%PER) -97dBm

Working Current/Voltage 120 mA@3.7V

Built-in LiPo Battery Working Current/Capacity 3.7V, 2000mAh

DJI Intelligent Battery

Type 3S LiPo Battery

Capacity 5200mAh, 11.1V

Charging Environment Range 0°C to 40°C

Discharging Environment Range -20°C to 50°C
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Section 2- DJI S1000 Specifications
11
12

Appendix B- Parachute Recovery System Specifications
13

Appendix C- Checklists

Section 1- DJI S1000 Checklists 
14
15
16
17

Section 2- DJI Phantom 2 Checklists
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