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); 9 1.407 (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 L AW 112

- 95)

Submitted this 19 th of May, 2015

William Granruth & Alexander Pugliese of Osprey Imaging, LLC.
261 Mill Street Greenwich, CT 06831
203

- 249

- 2342 william@ospreyimaging.com1

This page left intentionally blank2

William Granruth Osprey Imaging, LLC
2 6 1 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 T itle 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 System s ("UAS")

.

To Whom It May Concern:

I am respectfully submitting this request for an exemption from S ection 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 marin e 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 Connectic ut 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. A erial video s and photo graphs assist potential buyer s of property

in making an informed decision regarding their purchase. Many buyers targeted by Osprey view
these videos and photo s on the internet : the combination of aer ial and traditional photography
assists the buyers in noting the condition of structur al elements which otherwise would be out of

view.3

Unmanned Aerial System s

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 f eet above ground level (" AGL ") . Furthermore, the UA S 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 p ilot in command (" PIC ") . These restrictions, in combination with point

- of

- view video transmission and instrumentation

, ensure that Osprey's operations would not pose a h azar d to the National Aerospace System. Furthermore, an additional
crew member will confirm that a steri le area is maintained within a 2 00 ft

. radius of the air craft, 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 gra nted exemption s , 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.

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

S pecifications 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 wi ng aircraft, and are avid aviation enthusiast s. 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 wil l 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.4

7. Establish a s terile 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

contr ol 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. Permissi on from homeowner, landowner, or other property owner will be obtained prior to flight.

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

13. In the event the UAS loses signal, the built in programming will force the UAS t o retur n 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

Th e UAS operate s 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 wi th a current 3rd
clas s 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 standard s set forth in 14 C.F.R 61.113 A & B . The PIC will also undergo training that the FAA will require to ope rate 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

o bserver, a safety perimeter of 2 00 feet, battery levels above 80 % before flight, a full pre

- flight5

checklist and r un

- 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 restrict ed to daylight hours an d 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 area s of operation are trees, power lines, structures, street lights, and fences. Because o f 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 ha ve the capabilit y 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, t h e UAS will never be flown w ithin 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 res trictions prevent takeoff in a 6

- mile radius of a Class B airport

. If required b y 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 operati on.

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 no t carry a pilot, passenger s , or any flammable fuel, and the UAS operates in a fully

- restricte d and controlled envir onment, 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 "Experimen tal." 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

U nlike civil aircraft, the UAS does not carry living things on board; rather, it is controlled remotely
via a safe and restricted location. A s risks during operation of the UAS are negligible in co mparison6

to full

- scale aircraf t
, t he 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 thoro ugh 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 boar d 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 P IC communicates to the UAS via radio control. The FAA has approved exemptions for flight training without fully functional dual controls for a number of
air craft.

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 altimeter s . 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 minut es of powered flight. Given
that the UAS will never be further than 9 00ft 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 1 5 minutes of takeoff, or so as to ensure a minimum remaining batter y 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 mann er 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.7

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, wil l 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. Re gular 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 shou ld 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 compon ent replacements will be conducted by a manufacturer authorized technician.8

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 commercial ly for buyer education

purposes.

Approval of this exemption will ensure safe flight operations for Osprey's UAS following the strict guidelines set forth in th is request.

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

William Granruth Osprey Imaging, LLC.
2 6 1 Mill Street Greenwich, CT 06831
203

- 249

- 2342 william@ospreyima ging.com

Osprey respectfully submit s 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, operati on 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.9

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 °C10

Section 2

- DJI S1000 Specifications1112

Appendix B

- Parachute Recovery System Specifications13

Appendix C

- Checklists
Section 1

- DJI S1000 Checklists14151617

Section 2

- DJI Phantom 2 Checklists18