Certified Aerial Imaging LLC Owner: Shawn P. Ryan P.O. Box 607782 Orlando, FL 32860-7782 .. i ;·**~.** ··-**··~· ~** ..-· Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.105; 14 CFR 91.109; 14 CFR 91.119(c); 14CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, Shawn P. Ryan, operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its UAS, so long as such operations are conducted within and underthe conditions outlined herein oras may be established bythe FAA as required by Section 333. Commercial operation of UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

• Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

• Aerial video and/or photographyfor public and/orprivate use includingtelevision, public events, cinematography and news gathering.

• Aerial inspection/photographyof residential/commercial structures under contract with the owners or local government authority.

• Aerial inspection/photographyof residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

• Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster onlywhen the local authorities orgovernment has requested it by contract or donation.

• The abilityto offertrainingto persons individually or belongingto both private and/or public organizations that have interests in the use and application of a UAS forthe purpose ofthe safe operation ofa UAS to enhance the safety ofthe National Airspace System (NAS) as well as forthe protection ofthe persons and property. As described fully below, the requested exemption would permitthe operation ofa UAS under controlled conditions in the NAS thatwould be a) limited b) controlled c) predetermined and d) will provide safety enhancements tothe already safe operations in the industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

....establish requirements forthe safe operation of such aircraft systems in the national airspace system." The name and address ofthe applicant is: Name: Attn: Address: Email: Certified Aerial Imaging LLC Shawn P. Ryan, Owner/Chief Pilot 8040 Torro Ct, Orlando, FL 32860-7782 chromeshawn@gmail.com 

# 3$6-SB-1- 6J7oCertified Aerial Imaging LLC, will operate the DJI Phantom 3, with atotal weight ofapproximately 1280g or 21bs 13 oz. The dimensions are 40.36cm x40.36cm x 19.05cm or 16inch x 16inch x 7.5inch. Understill air the maximum speed is no more than 16m/sor 35mph with acruising speed of llm/sor 25mph. The DJI Phantom 3 has the abilityto hover and move along avertical and horizontal plane simultaneously. The DJI Phantom 3 has four motors, Motor Model DJI 3510, powered by a4480mAh 4s LiPo Lithium Polymer battery.There are four propellers, Propeller Model DJI 1345, in use. The DJI Phantom 3 will be controlled with the C3 remote controllerwith an operatingfrequency of2.400GHz- 2.483GHz. The live video feed will have an operating frequency of2.4GHz ISM with maximum range of 1.2 miles. The applicant will operate the UAS in line ofsight within aclosed off and predetermined area owned and/ operated bythe property representative. 

## DJI Phantom 3
GENERAL FEATURES 

## 0 

## 0 0 0 

## 0 0 0 0 0 0 0 0 0 Ready tofly 3-axis camera stabilization Precision flight and stable hovering GPS/GLONASS positioning 

### & auto return home On-screen real-time flight parameters High Definition Camera Camera tilt control Film straight down Supports Adobe DNG RAW Adobe lens profile support Camera parameter settings Album synchronization FAA no-fly zones locked outvia installed software TRANSMITIER 

## 0 0 0 

## 0 0 0 Operating Frequency:2.400 GHz- 2.483 GHz Communication Distance (open area) : CE: 2000m; FCC: 2000m Receiver Sensitivity (1%PER) :-101dBm 

### +/- 2dBm Transmitter Power: CE: 16dBm; FCC: 20dBm Working Voltage: 1.2A@ 7.4V Battery: 6000 mAh LiPo 2s CAMERA 

## 0 Operating EnvironmentTemperature: 0°C-40°C FOV: 94°/85° 

## 0 0 Sensor size: 1/2.3" 

## 0 HD Recording DJI VISION APP 

## 0 System Requirement of Mobile Device: iOS version 6.0 orabove/Android system version 4.0 or above

Given the small size ofthe UAS and the controlled environment provided, the proposed operations will adhere tothe Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grantofthe requested exemption is in the public interest. Accordinglythe applicant requests thatthe FAA grantthe requested exemption with minimum delay.

### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operational limitations proposed will provide for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions, to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as setforth in the Flight Operations Manual (FOM), include:

• The UAS will weigh less than 55 lbs. • The UAS will have a maximum operating speed of no morethan !OOmph. • Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer {VO). • Maximum flight timefor each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve or 20 minutes offlighttime whichever occurs first. • Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) or not more than 200 feet above an elevated platform from which filming is planned. • Minimum crew for each operation will consist ofthe UAS Pilot and the Visual Observer {VO). • The UAS pilotwill be the designated Pilot in Command {PIC) and will take and pass all applicable certifications currently being approved by the FAA. • A briefing will be performed regardingthe planned UAS operations priorto each day's flight consisting ofall the days' production activities. • All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only. • Ifoperations will be within a 5 mile radius ofthe geographic center/ Airport Reference Point (ARP) ofatowercontrolled or uncontrolled airport, the respective airports will be contacted advisingthem ofthe estimated flighttime, flight duration, elevation offlight and other pertinent information. • The operator will obtain verbal/written consent ofall persons involved with the planned operation and ensure thatonly consenting persons will be allowed within 100 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required underthe FOM. With the advanced permission of the FSDO, operations at closer range may be approved. • The PIC and VO will have been trained in operation of UAS and receive up-to-date information forthe particular UAS to be operated. • The PIC and VO will be able to communicate by voice, radio, and/ortext atall times. • Written and/orverbal permission and permits will be obtained, as applicable, from territorial, state, county orcity jurisdictions, including law enforcement, fire orotherappropriate governmental agencies. • Ifthe UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre-determined location within adesignated location and land autonomously. • The UAS will have the capability to abort aflight in case of unpredicted obstacles, weather, oremergencies. Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) {2) 14 CFR 91.103 14 CFR 91.105 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) 

### & (b) 14 CFR 91.405 (a) 14CFR 91.407 (a) (1) 14 CFR 91.409 (a) {2) 14 CFR 91.417 (a) & (b)14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) {1) 

### Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraftfrom the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated withoutan airworthiness certificate, in the restricted environmentand underthe conditions proposed will be at least as safe, orsafer, than aconventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs, fully loaded, carries neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured and designated area. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. These safety enhancements provide agreater degree ofsafetyto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry asubstantial external load. 14C.F.R. § 45.23 {b). Markingofthe Aircraft 

### The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sportcategory aircraft orexperimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption will be needed as the UAS will have no entrance to the cabin, cockpit or pilotstation on which the word "Experimental" can be placed. Given the size ofthe UAS, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by havingthe UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. 

### Pursuantto 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraft that is carrying passengers or propertyfor compensation or hire. An equivalent level ofsafety can be achieved by current Regulations because the applicant's UAS do notcarry any pilots or passengers nor property. The risks attendantto the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limitations setforth in the FOM will equate to the safe operation ofthe UAS.
14 C.F.R. §91.7{a): Civil Aircraft Airworthiness. 

### The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety check lists priorto each flight, an equivalent level ofsafety will be provided.14C.F.R. § 91.9 {b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) F<?r which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft, not only because there is no piloton board, but because there is no room orcapacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control pointwhere the pilotflying the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command totake certain actions before flightto insurethe safety offlight. As FAA approved rotorcraftflight manuals will not be provided forthe aircraft an exemption will be needed. The PIC will take all actions as stated in the manufacturer FOM in the pre-flight inspection section, including but not limited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 14 C.F.R. §91.105: Flight crew members at stations Exemption may be required, the PIC may not leave his station norshall VO leave station

. In eventthat PIC orVO become incapacitated, UAS is to automatically return to designated landing area, as outlined in FOM.

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person mayoperate acivil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, bytheir design do not have fully functional dual controls. Flight control is accomplished through the use ofacontrol box thatcommunicates with the aircraft via radio communications. The FAA has approved exemptions forflighttraining withoutfullyfunctional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. The equivalent level ofsafety provided by the factthat neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As setforth herein, the UAS will never operate at higherthan 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph astructure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest pointon the structure. Itwill however be operated in a restriCted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained consent. The equivalent level ofsafety will be achieved given the 

### size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraftor rotorcraftweightingfar more than the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraftoperating at or below 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between these UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119.14C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airportor an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead aGPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuantto the safety check list and live flight data monitoring, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first pointof intended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly afterthatfor at least 30 minutes; or (2) At night, to fly afterthatfor at least 45 minutes." The battery poweringthe UAS provides approximately 25 minutes of powered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longertimeframe forflight in daylightortwilightVFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of priorexemptions. Operatingthe UAS, in a tightly controlled area where only people and propertyowners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does notengender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 20 minutes or 25% of battery power- whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate acivil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate acivil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs no more than 55 lbs. and is operated withoutan onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the UAS. An equivalent level ofsafety will be achieved by keeping these documents atthe ground control pointwhere the pilotflyingthe UAS will have immediate access to them; to the extentthey are applicable tothe UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require that an aircraft operatororowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese section and Part 43 apply onlyto aircraftwith an airworthiness certificate, these sections will notapply to theapplicant. Maintenance will be accomplished by the operator pursuantto the flight manual and operating handbook. An equivalent level ofsafety will be achieved because the UAS is very limited in size and will carry asmall payload and operate only in restricted areas for a limited period oftime. If mechanical issues arise the UAS can land immediatelyand will be usually operating from no higherthan 400 feetAGL. The operatorwill ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthycondition to provide the equivalent level ofsafety. An equivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operatorwill ensure thatthe UAS is in working order priorto initiating flight and perform required maintenance needed.

Additional Information: Certified Aerial Imaging's pilots are all certified pilots with extensive and current knowledge ofthe NAS. The primary pilot, Shawn P. Ryan, has 6+ years of recreational UAS experience and an in-depth understanding ofthe capabilities and safety concerns involved in usingthis technology as an asset tothe community. Satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2012 provide more than adequatejustification forthe grantofthe requested exemptions allowingthe commercial operation of the applicant's UAS.

# ~ Shawn P. Ryan