SteelBook Shop LLC

2703 Cassidy Ct

Winchester, VA 22601

540-931-7799

Dear Sir or Madam,

In response to the letter dated November 25, 2015, I am resubmitting my exemption request 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. Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14

C.F.R. §§ Part 21; 45.23(b); 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.151(a);

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

SteelBook Shop LLC will utilize a DJI Phantom 3 Professional Quadcopter for photography and

videography for hire in Virginia and West Virginia. The purpose would be primarily for real estate

presentations, but include inspection and "for hire" aerial photography.

Breakdown of codes:

14 C.F.R. § 21, 14 C.F.R. § 91 and 91.151: Airworthiness Certificates, Manuals and the Like14 C.F.R. § 21,

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary

airworthiness certificates in relation to FAR § 91.203(a) (1). The size, weight and enclosed operational

area of the UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent

level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from

the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section

333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness

certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to

areas such as airports and dense populations. The DJI Phantom P3 Professional meets and/or exceeds

each of the elements.

14 C.F.R. § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or

passengers, and given the size of the UAS, this Regulation is inapplicable. An equivalent level of safety

will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined.

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299,

9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable as the DJI Phantom 3 UAS utilizes

electronic global positioning systems with a barometric sensor.
14 C.F.R. § 91.151(a) with the condition that the PIC does not begin a flight unless (considering wind and

forecast weather conditions) there is enough power to fly to the first point of intended landing and,

assuming normal cruising speed, land the UA with 30% battery power remaining.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations.

They are inapplicable for the same reasons described above. The equivalent level of safety will be

achieved by the operator, Jeremy Berkebile

14 C.F.R. § 45.23: Marking of the Aircraft

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications.

The DJI Phantom 3 Professional is unmanned. Therefore does not have a cabin, cockpit or pilot station

on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small

aircraft with dimensions smaller that minimal lettering requirement. My DJI Phantom 3 Professional

does have my name, and phone number affixed to the underbelly of the UAS. Regardless, I will mark the

UAS in the largest possible lettering by placing my business name on its fuselage as required by 14 C.F.R.

§ 45.29 (f) so that I will see the markings. The FAA has previously issued exemptions to this regulation

through Exemptions Nos. 8738, 10167,10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC Pursuant to 14 C.F.R. § 61.113 (a) & (b),

private pilots are limited to noncommercial operations. I can achieve an equivalent level of safety as

achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while

helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation

of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61,

et seq. Thus allowing me to operate my UAS in a manner that meets and exceeds current safety levels in

relation to 14 C.F.R. § 61.113 (a)& (b).

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

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be

operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than

400 AGL, safely below the standard of 400 AGL. The DJI Phantom 3 Professional will operate away from

public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum

safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher

level of safety will be achieved.

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

Inspections

The above-cited Regulations require, amongst other things, aircraft owners and operators to have the

aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except

as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this

chapter. These Regulations only apply to aircraft with an airworthiness certificate. They will not,

therefore will not apply to The DJI Phantom 3 Professional. However, as a safety precaution, I will,
inspect my UAS before and after each flight.

The battery life on The DJI Phantom 3 Professional is 21 minutes or less, so most flights will be limited to

15 minutes and a complete log will be held and available upon request.

Public Interest:

Aerial photography and videography , in the past, required fixed wing aircraft or helicopters and a pilot

to accomplish at an expensive cost. My service would provide low cost photography while achieving the

same level of professionalism as a piloted aircraft. My photography and increased business will add tax

dollars to the local economy and possibly lead to more jobs in the field as a result of business growth. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS

into the national airspace system, hence the passing of the Reform Act. The Phantom 3 is lithium

battery powered and creates no emissions that can harm the environment. My photography and videos

would be shared, free of charge through public social media platforms at my discretion so it would

educate future UAS pilots and create an interest in the field.

Safety:

Flying an UAS through airspace is much safer than airplanes as it uses no combustible fuel and there

would be limited public safety concern in the event of a failure with The DJI Phantom 3 Professional. The

The DJI Phantom 3 Professional will always be flown in a manner that complies with FAA regulations

and always have eye contact or line of sight with the UAS. The DJI Phantom 3 Professional uses GPS

enabled technology, so in the event of a communication failure it will automatically return to the liftoff

point and land safely. I will only operate the UAS in areas of low population and avoid obstructions. I will

obtain all necessary permissions before flying and recording on private property.

Summarization of request for Federal Register:

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register,

should it be determined that publication is needed: SteelBook Shop LLC seeks an exemption from the

following rules for the commercial operation of a small unmanned aerial system for real estate

photography and distribution in the marketing, inspection and displaying of real estate.

14 C.F.R. §§ Part 21; 45.23(b); 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.151(a);

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

The exemption will enhance safety by reducing risk to the operator, the general public and property

owners from the substantial hazards associated with performing equivalent work using traditional

conventional aircraft and rotorcraft. SteelBook Shop LLC requests that the FAA grant this petition using

the "summary grant" process such that publication in the Federal Register is not required. This petition

would not set a precedent, and any delay in acting on this petition would be detrimental to the

petitioner. The aircraft will NOT operate outside the USA.

The granting of the above mentioned exemptions would allow this.
Respectfully Submitted,

Jeremy Berkebile

 Jeremy Berkebile