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 Like 14 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 exceed s 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, 9 299A, 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 wit h 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 requi rement. 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 prev iously 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 bec ause my UAS does not carry any pil ots 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 altitude s 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 ap ply 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 p hotography 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 l o ca l 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 comb ustible 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 enable d technology, so in the event of a co mmunication 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: SteelBo ok 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 u sing 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 de lay 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