### September 25, 2015

Exemption No. 12994 Regulatory Docket No. FAA

− 20 15

− 2742

Mr. David E. Altobelli Eagle Drone Imaging, LLC 11 Ascot Park Nashua, NH 03063

Dear Mr. Altobelli :
This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated June 25, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Eagle Drone Imaging, LLC (hereinafter petitioner or operator) for an exemption

. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct photography and videography of industrial structures, real estate, and nature/scenic settings.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision+, DJI Inspire 1, and a DJI Spreading Wings S1000+.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria

### 2

provided in Section 333 of Public Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21

, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is
not necessary.

The Basis for Our Decis ion

You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

− 2014

−0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11 062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Eagle Drone Imaging, LLC is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

Conditions and Limitations

In this grant of exemption, Eagle Drone Imagin g , LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 Vision+, DJI In spire 1, and the DJI Spreading Wings S1000+ when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are
not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restri ction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer hi s or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and li mitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between th e conditions and limitations in this exemption and the procedures outlined in the operating documents,

### 4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies , e.g. , inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

### 5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles fro m the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a
pre

- determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the enclosed COA

.

### 6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

### 7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Stan dards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certifi cate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;
g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes
essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specifi ed in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8

This exemption terminates on September 30, 2017 , unless sooner supersede d or rescinded.

Sincerely, /s/ John S. Duncan Director, Flight Standards Service

EnclosuresJune 25, 2015 

### Eagle Drone Imaging, LLC Contact: David E. Altobelli 11 Ascot Park Nashua, NH 03063 Email Daltobelli1@mac.com Phone (603) 305-7705

U.S. Department Of Transportation Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590

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

ofthe Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the reform act) and 14 CFR Part 11, 

### Eagle Drone Imaging, LLC, a company that owns and operates Small Unmanned Aircraft Systems (UAS), requests to be exempted from the Federal Aviation Regulations (FAR) listed below so that 

### Eagle Drone Imaging, LLC may operate UAS commercially in airspace regulated by the FAA, as long as such operations are conducted within and under the conditions outlined herein or as maybe established by the FAA as required by Section 333.

Company Background and Planned Operations 

### Eagle Drone Imaging, LLC is a New Hampshire company owned by David E. Altobelli. Mr. Altobelli is a commercially rated helicopter pilot, with a current medical certificate and flight review, and nearly 320 hours as PIC. He also has an estimated 25 hours of experience flying UAS and is familiar with the operations and the maintenance of the hardware and software updates for these systems. Operations will involve collection of aerial imaging and sensor data to enable inspections and assessments of industrial structures, agricultural management and
surveys, and photography and videography (e.g. land and water based venues for imaging real-estate, naturaljscenic settings, outings, functions and events).

Equivalent Level of Safety The requested exception would permit the operation of a lightweight (less than 55 lbs. total takeoff weight) UAS under controlled conditions for commercial use by a certified commercial helicopter pilot thereby enhancing safety and fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibility to" establish requirements for safe operation of such aircraft systems in national airspacesystems", Section 333 (c) of the Reform Act. The enhanced safety using a UAS in comparison to a manned aircraft, including helicopters of significantly greater proportion and carrying a crew with flammable fuel is self-evident and beneficial to the public's interest, while being able to provide commercially beneficial information and data more quickly, accurately, safely and economically with greatly reduced environmental impact. All operations will be conducted from safe and appropriate distances for the specific operation. All operations will be performed with the public's safety and right to privacy safeguarded at all times.

UAS Devices Eagle Drone Imaging's UAS(s) are battery-powered, weighing well less than 55 pounds including payload. Our UAS fleet will include the DJI Phantom Series, the DJI Inspire Series, and the Spreading Wings Series of RC multi-prop helicopters. The specific UAS(s) to be initially included in our fleet:

Parameter DJI Phantom 2 DJI Inspire 1 Spreading Wings Vision Plus S1000+ Type 4 Prop RC helicopter 4 Prop RC helicopter 8 Prop RC helicopter Weight 2.71bs. 6.471bs. 24.2 lbs. max Flight Speed (max1 29 knots 42 knots 42 knots Flight Time 20min. 18min. 15 min. Camera Integrated Integrated DSLRcamera
They operate at speeds well less than 87 knots and have the capability to hover and

move in the vertical and horizontal planes simultaneously in a precisely controlled

manner. Our primary intent is to utilize them at much slower speeds for our imaging and data collection applications. As upgrades become available, we would like to be able to incorporate the more advanced systems in each series into our operations after we have thoroughly reviewed new documentation and have trained to be capable and comfortable with their flying characteristics.

Statutory Authority for Exemptions Eagle Drone Imaging, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relief from any currently applicable FAR'S operating to prevent Eagle Drone Imaging, LLC from future commercial use of small UAS to operate in the national airspace system as described below. The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public's interest to do so. Eagle Drone Imaging, LLC's UAS(s) will meetthe definition of"small unmanned aircraft" as defined in Section 331 and therefore the integration of these UAS are expressly contemplated by the Reform Act. Eagle Drone Imaging, LLC would like to operate its' light weight UAS( s) prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion of the rule making required under Section 332 of the reform Act. Inmaking this determination, the Secretary of Transportation is required to determine which UAS do create a hazard to users of the national airspace system or the public

or pose a threat to national security in light of the following:

-The UAS size, speed, weight and operational capability

- Operation of the UAS in close proximity to airports and populated areas -Operation of the UAS within visual line of sight of the operator
Reform Act 333(a). If the secretary determines that such vehicles "may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.


### Eagle Drone Imaging, LLC utilizes multi-prop RC helicopters weighing less than SSlbs. that operate at speeds less than 50 knots and have the capability
to hover and operate in the vertical and horizontal plane simultaneously in a precisely controlled manner. The UAS will operate only within the visual line-of-sight of the operator within a controlled flight area and at 400 feet above ground level (AGL) or less. Most operations are envisioned at less than 100 feet AGL. These will not present a hazard to the national airspace nor the public.

The very small nature of these UAS combined with the risk management presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allowing commercial operations of UAS to commence immediately. Also due to the size of UAS and the controlled areas and the low altitudes in which they will operate, approval of this exemption presents no national security issues and absolutely minimal safety concerns which have been mitigated through our risk management process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UAS verses traditional aircraft as well as the economic impact of greatly reducing the cost of aerial data and imaging acquisition thereby benefits the greater public's interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.Regulations For Exemption Request Eagle Drone Imaging, LLC respectfully requests the grant of an exemption to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use:

Regulation Brief Description

14 CFR 21, subpart H Air Worthiness Certificates
14 CFR 45.23 (b) Identification and Registration Marking
14 CFR 91.7 (a) Civil Aircraft Worthiness
14 CFR 91.9 (b) (2) Civil aircraft flight manual, marking, and placard requirements
14 CFR 91.103 (b) Preflight action
14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight
tests
14 CFR 91.119 Minimum safe altitudes
14 CFR 91.121 Altimeter settings
14 CFR 91.151(a) Fuel requirements for flight in VFR conditions
14 CFR 91.203(a) &(b) Civil Aircraft: Certifications required
14 CFR 91.405(a) Maintenance required
14 CFR 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration.
14 CFR 91.409(a)&(b) Inspections

A more detailed request for regulation exemptions is provided in Appendix A below.

Operational Risk Management: Conditions and Limitations

The following are our proposed procedures and limitations for the flight operations of Eagle Drone Imaging, LLC. These proposed guidelines will be modified as such from recommendations provided by the FAA in conjunction with the submission of this request:

1. Flights will only occur during the daytime hours. 2. Flights will be operated in the visual line-of-sight (VLOS) of the operator (PIC) and the visual observer (VO) using human vision with no supplemental devices other than corrective lenses. 3. Flights will be terminated at any time the weather and wind deteriorate to being "unsafe for flight" based on manufacturers recommendations and the PIC's experience. Operations will follow the anticipated guidelines of thisexemption (operations under visual meteorological conditions-VMC, and standard visual flight rules- VFR) 4. All documents, manuals and maintenance logs associated with the UAS will be present on the site of operations. In addition, the credentials of the PIC (pilot certificate, pilot logbook with current flight review, current medical, and proper identification) will be available onsite. 5. The UAS will be assessed for airworthiness by the PIC prior to each flight session using a checklist derived from the manufacturers manual. All
necessary calibrations and testing prior to the flight session will be performed. 6. The UAS will weigh less than 55 lbs. with speeds well less than 87 knots. 7. Flights will be operated at 400 feet AGL or less, or as defined from the
outcome of this request for exemption. 8. Crew will be at a minimum of the operator (PIC) and an observer and/or

camera operator (VO). The PIC will be responsible for flying the UAS and monitoring its status and flight dynamics, while maintaining line of sight visualization and keeping the system operations within the specified factory limits (e.g. flight range, battery power, etc.). The VO will be involved in monitoring the airspace for other aircraft, the ground for unintended vehicles and bystanders, and will also look for additional hazards that could compromise safe operations. 9. Operator (PIC) and crew, including the VO will remain in voice contact during the entire flight operation 10. Prior to operations, weather forecasts, weather radar, and air traffic patterns for the area will be reviewed. The proximity of the intended location with respect to airports and TFRs will be determined using Foreflight software on our iPad or mobile phones. If operations are anticipated within 5 nautical miles of airport reference points, the airport management or Air Traffic Control (ATC) tower will be notified prior to the operation, identifying the location, anticipated time, and the intent of flight operations. We will also have available a hand-held portable radio to enable monitoring oflocal air traffic and to establish, if necessary, communication with the local tower. When in the vicinity of non-towered airports, we will monitor air traffic in the area and be able to inform them of our operations as needed. 11. The UAS PIC will perform a final check of the flight area and make certain of the safety of all persons present and property in the controlled area prior to initiating flight operations. 12. All UAS will have the capability to return automatically to the operator in a safe manner in the event oflost RC communication or a system problem. The auto-return function will be checked and verified for proper operation

on a regular basis. A starting GPS home-position will be established prior
to continuing each new flight. 13. The UAS will have indicators on the control and/or displays to inform the operator of the UAV's distance away from the operator, its altitude and velocity, and its remaining battery power.14. Written and/or oral permission from the relevant property holders will be obtained when flights are conducted over private or controlled access property.



### Benefits to the Public 

### as a Whole
Approval of these 333 exemptions in general would allow commercial operations of small UAS to provide numerous services that would benefit from aerial imaging and data collection while greatly enhancing safety by reducing the overall risk associated with traditional aircraft. Traditional aerial imaging requires large aircraft, such as helicopters, with flammable fuel to fly in close proximity of populated areas and people and often in sub-optimal states of their height-velocity curves. With the use of small UAS of 55 lbs. or less that

are battery operated and flying below 400 feet AGL, the risk of injury of people

on the ground or the crew is greatly minimized in comparison. The granting of the use of these small UAS by 

### Eagle Drone Imaging, LLCwill allow companies like ours to grow and provide career opportunities while also enabling safe and beneficial free enterprise services that would assist other companies in their business and also provide enjoyment and information to the general public.


### Eagle Drone Imaging, LLC respectfully requests the FAA grant its exemption without delay. The FAA has the authority to issue the exemption sought by 

### Eagle Drone Imaging, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Please contact me ifl can provide additional information and clarity to help expedite the process.

Eagle Drone Imaging, LLC 11 Ascot Park Nashua, NH 03063 Dalto belli 1 @mac.com Cell603-305-7705

Commercial Pilot Rotorcraft-Helicopter Certificate Number: 3358875 (20 Nov 2010)

### Appendix A: Regulations for Requested Exemption

Regulation Code Brief Regulation Description Justification for Regulation Description Exemption 14 CFR21, Air Subpart H, entitled Airworthiness Given the size, weight and defined subpartH, Worthiness Certificates, sets forth requirements area of operations for Eagle Drone 14 CFR §91.203 Certificates for procurement of necessary Imaging, LLC UAS flights permits (a) (1) airworthiness certificates in relation exception from Part 21 because they
to FAR §91.203(a)(1). meet an equivalent level of safety pursuant to Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. The UAS to be operated are less than 55 lbs. fully loaded, carry neither pilot nor passenger, carry no explosive materials or flammable fuels, and operates within a secured controlled area. Operations under this exemption will be tightly controlled and monitored to ensure safe operations.

14 CFR §45.23 Marking of The regulation requires: When Even though the UAS will have no (b) Aircraft marks include only the Roman airworthiness certificate, an capital letter "N" and the exemption may be needed as the registration number is displayed on UAS will have no entrance to the limited, restricted or light-sport cabin, cockpit or pilot station on category aircraft or experimental or which the word Experimental" can provisionally certificated aircraft, be placed. Given the size of the UAS, the operator must also display on two-inch lettering will not be that aircraft near each entrance to possible. The word "Experimental" the cabin, cockpit, or pilot station, in will be placed on the fuselage in letters not less than 2 inches nor compliance with §45.29 (f). The

more than 6 inches high, the words equivalent level of safety will be "limited," "restricted," "light-sport," provided by having the UAS marked "experimental," or "provisional," as on its fuselage as required by §45.29 applicable. (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A. If required, the N registration number will also be displayed on the fuselage in a font size appropriate for the dimension ofthe device for identification purposes.

14 CFR §91.7 (a) Civil Aircraft The regulation requires that no Given the size of the aircraft and theWorthiness person may operate a civil aircraft requirements contained in the unless it is in airworthy condition. Manufacturers Operating Manual for As there will be no airworthiness maintenance and use of safety certificate issued for the aircraft, checklists prior to each flight, an should this exemption be granted, equivalent level of safety will be

no FAA regulatory standard will provided. exist for determining airworthiness.

14 CFR §91.9 (b) Civil aircraft No person may operate a U.S.- The UAS, given its size and (2) flight manual registered civil aircraft

... (2) For configuration has no ability or place which an Airplane or Rotorcraft to carry such a flight manual on the Flight Manual is not required by aircraft, not only because there is no §21.5 ofthis chapter, unless there is pilot on board, but because there is available in the aircraft a current no room or capacity to carry such an approved airplane or Rotorcraft item on the aircraft. Flight Manual, approved manual The equivalent level of safety will be material, markings, and placards, or maintained by keeping the flight
any combination thereof. manual at the ground control point where the pilot flying the UAS with immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299,9299A, 9565,9565B,10167,10167A, 10602, 32827, and 10700.

14 CFR §91.103 Preflight This regulation requires each pilot Flight information such as runway (b) action in command become familiar with distances and flight performance are all information concerning that not relevant to the operation of UAS. flight including runway distances The equivalent action is that the PIC and takeoff and landing distances, will review airspace considerations, with this data provide in FAA weather, flight battery requirements, approved rotorcraft flight manuals land and property boundaries with will not be provided for the aircraft respect to takeoff and landing

an exemption will be needed. locations. Manuals for the UAS will present on site of all operations.

14 CFR §91.109 Flight This section provides that no person UAS are remotely piloted aircraft, by instruction; may operate a civil aircraft (except a their design do not have fully Simulated manned free balloon) that is being functional dual controls. Flight instrument used for flight instruction unless control is accomplished through the flight and that aircraft has fully functioning use of a control box that certain flight dual controls. communicates with the aircraft via
tests radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety

can be achieved as neither a pilot

nor passengers will be carried in the aircraft in addition to the small size and low speed ofthe aircraft.

14CFR§91.119 Minimum Section §91.119 establishes safe This exemption is for a UAS that is a safe altitudes altitudes for operation of civil RC multi-prop helicopter with the aircraft. Section §91.119 (d) allows exemption requesting authority to helicopters to be operated at less operate at altitudes up to 400 AGL. than the minimums prescribed, The equivalent level of safety will be provided the person operating the achieved given the size, weight, andhelicopter complies with any route speed of the UAS as well as the

or altitudes prescribed for location where it is operated. No helicopters by the FAA. flight will be taken without the permission ofthe property owner or local officials.

14 CFR §91.121 Altimeter This regulation requires each The UAS typically may not have a settings person operating an aircraft to barometric altimeter, but instead a maintain cruising altitude by GPS altitude read out, an exemption reference to an altimeter that is set may be needed. An equivalent level "

... to the elevation ofthe departure of safety will be achieved by the airport or an appropriate altimeter operator, pursuant to the Manual setting available before departure." and Safety Check list, by receiving altitude information via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established, recorded and confirmed for accuracy by the pilot.

14CFR Fuel Section §91.151 (a) prohibits an The battery powering the UAS §91.151(a) requirements individual from beginning "a flight provides approximately 20 minutes for flight in in an airplane under VFR conditions of powered flight. To VFR unless (considering wind and meet the 30 minute reserve conditions forecast weather conditions) there requirement in 14 CFR §91.151, UAS is enough fuel to fly to the first point flights would not be practical. Given of intended landing, and, assuming the limitations on the UAS's normal cruising speed- (1) During proposed operations are within the the day, to fly after that for at least "line-of -sight" distances, flight 30 minutes; or (2) At night, to fly durations will instead be determined after that for at least 45 by remaining battery life. minutes." Telemetry indicators provide indication of remaining battery life. At 2 5 percent remaining battery life, the sequence to bring operations to completion will be initiated. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745,10673, and 10808.

14CFR Civil Aircraft: The regulation provides in pertinent The UAS fully loaded weighs no §91.203(a) &(b) Certifications part: more than 55 lbs. and is operated required (a) Except as provided in§ 91.715, without an onboard pilot. As such,

no person may operate a civil there is no ability or place to carry aircraft unless it has within it the certification and registration following: documents or to display them on the (1) An appropriate and current UAS. An equivalent level of safety airworthiness certificate

.. will be achieved by keeping these (b) No person may operate a civil documents at the ground control aircraft unless the airworthiness point where the pilot flying the UAS certificate required by paragraph will have immediate access to them, (a) ofthis section or a special flight to the extent they are applicable toauthorization issued under §91.715 the UAS. The FAA has issued is displayed at the cabin or cockpit numerous exemptions to this
entrance so that it is legible to regulation. A representative sample
passengers or crew. of other exceptions includes Exemption Nos. 9565,9665, 9789, 9789A,9797,9797A,9816A,and 10700.

14CFR Operation These regulations require that an Given that these sections and Part 43 §91.405(a) after aircraft operator or owner "shall apply only to aircraft with an §91.407(a)(1) maintenance, have that aircraft inspected as airworthiness certificate, these §91.409(a)&(b) preventive prescribed in subpart E of this part sections will not apply to the maintenance, and shall between required applicant. The operator pursuant to rebuilding, or inspections, except as provided in the flight manual and operating alteration. paragraph (c) of this section, have handbook will accomplish discrepancies repaired as maintenance. Software and firmware prescribed in part43 of this will be maintained with current chapter

... ," and others shall inspect versions. As the manufacturer does

or maintain the aircraft in not provide specific maintenance compliance with Part 43. instructions, maintenance will be "on condition" for all aircraft and each aircraft will have a maintenance log.

References Part 91 we blink General Operating and Flight Rules Part45 we blink Identification and Registration Marking Petitioning weblink for Exemption Under Section 333