16 September 2015

Hon. Michael Huerta

Administrator

Federal Aviation Administration

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

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

the Federal Aviation Regulations from certain parts of the FARs.

Dear Administrator Huerta:

Pursuant to Section 333 of the FAA Modernization and Refo rm Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, Troy A. Balding (or the “Petitioner” ), hereby applies for a summary exemption from the

listed Federal Aviation Regulations (“FARs” ) to allow him to operate small Unmanned Aircr aft Systems

(“ s UAS”) for aerial data colle ction, under the conditions and limitations set forth in this Petition.

The requested exemption would permit the operation of small, unmanned and relatively inexpensive

s UAS under controlled conditions in airspace that is (1) limited, (2) predetermined, and (3) would

provide safety enhancements to the already safe n ews gathering operations presently using manned

helicopters and airplanes. Approval of this exemption would thereby enhance safety and fulfill the FAA

Administrator’s responsibilit ies to “...establish requirements for the safe operation of such aircraft

syst ems in the national a irspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant and his Counsel:

Troy A. Balding

9558 Beauclerc Cove Road

Jacksonville, FL 32257

386

- 216

- 8407

satroyb@gm ail.com

Regulations from wh ich the exemption is requested:

14 CFR Part 21

14 C.F.R. § 45.23(b)

14 CFR § 61.3

14 C.F.R. § 91.7 (a)

14 CFR § 91.9 (b) (2)

14 C.F.R. § 91.103

14 C.F.R. § 91.109

14 C.F. R. § 91.119

14 C.F.R. § 91.12114 CFR § 91.151 (a)

14 CFR § 91.203 (a) & (b)

14 CFR § 91.205(b)

14 CFR § 91.215

14 CFR § 91.405 (a)

14 CFR § 407 (a) (1)

14 CFR § 409 (a) (2)

14 CFR § 417 (a) & (b) 3

The Appendix describes the FARs from which an exemption is requested and summarizes the

justification for each re quested exemption.

The Petition is submitted to fulfill Congress’ goal under Se ction 333(a) through (c) of the Reform Act,

which directs the Secretary of Transportation to consider whether cer tain unmanned aircraft systems

may operate safely in the nation al airspace system (NAS) before completion of the rulemaking required

under Section 332 of the Reform Act. In making this determination, the Administrator must determine

which types of s UASs do not create a hazard to users of the NAS or the public or pose a threat to

national security in light of the following:

• The s UAS’s size, weight, speed, and operational capability;

• Operation of the s UAS in close proximity to airports and populated areas; and

• Operation of the s UAS within visual line of sight of t he operator.

Reform Act § 333 (a).

If the Administrator determines that such vehicles “may operate safely in the national a irspace system,

the Secretary shall establish requirements for the safe op eration of such aircraft in the national airspace

system. ” Id. § 333(c) (emphasis added). The Secretary has delegated his aviation authority to the

Administrator of the FAA. The Federa l Aviation Act expressly grants the FAA the authority to grant

exemptions from its regulatory req uirements for civil aircraft, a term defined under §40101 of the Act,

which includes sUASs. The Administrator may grant an exemption from a requirement of a regulation

prescribed unde r subsection (a) or (b) of this section or any sections 44702

- 44716 of the Federal

Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) See a lso 49

USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1).

Summary of Request:

As a long time radio control pilot, I am requesting an exception, and permission to use my s UAS, DJI

Phantom 2 Vision (further in this report are the detailed specifications of the s UAS), for the purpose of

taking aerial photos and videos for commercial in terests in providing services to cli ents using a small

advanced sUAS in the following areas: Real Estate, Marketing, Land Management/Surveying, and

Special Events. A ll sUAS flights will occur over private or controlled access property and will do so with

the property owner's consent and knowledge and that only people who have consented or otherwise

have agreed to be within the s UAS’ radius during filming and photography applications.Why the exemption would not adversely affect safety:

This can be done ve ry safely in a controlled environment, on private property, with limited airtime

required, extremely low noise, in uncongested areas. The s UAS will always be operated in a Visual Line

of Sight (VLOS) environment, with an observer, and always under 400 feet

.

Prior to flight, I go through a “pre

- flight” checklist:

1. verify propellers are properly secured and not damaged.

2. ensure all batteries are fully charged

a. s UAS battery

b. Transmitter/controller battery

c. Wi

- Fi range extender battery

3. turn on tr ansmitter & range extender

4. turn on s UAS battery

5. initiate a “calibration” procedure for the Compass

6. place s UAS in a safe position on the ground for takeoff

7. turn motors on

8. verify there are 6 or more satellites acquired

9. initiate takeoff

10 . hover at 10

– 15 feet and verify all controls are operating properly

11. initiate flight plan, as required

12. upon completion of flight plan, ensure a safe environment exists for a safe landing, and inspect s UAS

prior to another flight for air worthiness

Description of s UAS:

The DJI Phantom 2Vision ( s UAS) operates on 5.8 GHz, and weighs 2.7 pounds. Se rial # PH645426151

. It

has a very sophisticated flight cont rol system (DJI NAZA

– M V2), and includes a Gyro, Compass, GP S, and

camera that is on a single axi s gimbal. The flight system includes a “Failsafe” function, where if signal is

lost, or interference occurs with the controller, or it fly’s out of range, the s UAS will automatically return

to its “h ome” position. It also provides altitude & radius flight adjustment settings, for maximum height

and distance.

It will also “altitude hold

- auto hover” if radio control sticks are rele ased. And, in order to increase flight

safety and prevent accidental flights in restricted areas, the new firmware for the Phantom 2 series

includes a “No Fly Zone” feature. These zones have been d ivided into two categories: A

- large

international airports and, B

- small local airports. http://www.dji. com/fly

- safe/category

. Exceeding the

control range of the remote control will trigger ‘Return

- to

- Home’, meaning the Phantom 2 Vision will

automatically fly back to its takeoff point and land safely.

Using Wi

- Fi and a Wi

- Fi Range Extender, the camera trans mits liv e video to my Apple iPhone 6 Plus or

Samsung Galaxy S3 , all of which comply with FCC requirements. The DJI Vision App shows, altitude,

direction of flight, distance from home, speed, location, number of s atellites acquired, and battery level.Pi lot in Command (PIC) Background and experience:

I have approximately 5 years experience in flying radio control and wire controlled s U AS aircraft. My

current inventory totals 3 electric aircraft. Furthermore, I have over 6 years active duty as a Naval Flig ht

Officer f ly ing on the P

- 3C Orion, so I am thoroughly familiar with flight rules, regulations, and the

importance of checklists. I am still active duty , have over 1,35 0 flight hours, and still in a flying status. I

have always been intrigued with any new technology, an d generally hav e always been an early adopter.

I would like to take adv antage of my hobby skills, in a commercial way, and help generate interest within

the general public in the safe application of sUAV’s . I have been into video and photography, as a hobb y,

my entire life. This new technology ties together, both of my long time hobbies. I am currently in

process of getting my Sport Pilot Certificate, and I hold a valid driver’s license from the State of Florida

.

Why the public would be served by granting this exemption:

I believe this is a technology that can benefit realtors and commer cial businesses, in a huge way. The

industry is anxious to have this technology enhance their ability to market properti es from a totally new

perspective, because the aerial perspective is very impressive. By increasing their marketing potential it

can increase home sales, benefi ting Realtor, buyer and seller. For the commercial business owner, that

new aerial perspective can increas e market awa reness and growth, with greater recognition of business

messag e, physical presence, inventory (in the case of an auto dealer) and location.

The Petition to use a s UAS for aerial data collection and its proposed limitations are similar in all

material respects to those approved by the FAA in Grants of E xemption Nos. 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 Dock et No. FAA−2014−0382), 11213 to Aer yon Labs, Inc. (see Docket No.

FAA−2014−0642) and 11310 to Colin Hinkle (see Docket No. FAA

- 2014

- 0608). In those grants the FAA

found that the enhanced saf ety 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 gre ater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause

to find that the s UAS operation enabled by this exemption is in the public interest.

The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213, and

11310 also apply to the situation presented by this Petition.

Very r espe ctfully

,

Troy A. BaldingAPPENDIX

FAR section Subject Justification

14 CFR § 45.23(b) R equirement to display Insufficient space on

registration number on vehicle

vehicle

14 CFR Part 21 Aircraft certification Designed for manned

requirements and aircraft; not suitable for off the

- shelf

procedures s UAS

14 CFR § 61.3 Requirement for pilot Part 61 requirements

C ertificate designed for manned

aircraft, not s UAS; petition

describes training for s UAS operator

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned

aircraft; n ot suitable for off the

- shelf

s UAS

14 CFR § 91.9 (b) (2) Requirement for manual to No one aboard to read

be available in the cockpit manual

14 CFR § 91.103(b) Requirement for crew Unmanned vehicle

members to be onboard

14 CFR § 91.109 Requirement for dual No one aboard to operate

controls during flight controls

instruction

14 CFR § 91.119 Minimum altitudes for safe Safety requires operation

F light below these altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read

altimeter

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel

14 CFR § 91.203 (a) & (b) Requirement for No one aboard to read

registration and certificates

airworthiness certificates to

be onboard

14 CFR § 91.205(b) Cockpit instruments No one aboard to read14 CFR § 91.215 Transponder requirement Vehicle has insufficient

useful load; will be

operated below ATC radar

coverage

14 CFR § 91.405 (a) Inspection requirements Designed for manned

aircraft; not suitable for off the

- shelf

s UAS

14 CFR § 91.407(a) (1) Inspection approval Designed for manned

R equirements aircraft; not suitable for off the

- shelf

s UAS

14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned

aircraft; not suitable for off the

- shelf

s UAS

14 C FR § 91.417 (a) & (b) Maintenance records Designed for

R equirements manned aircraft; not

suitable for off the

- shelf

s UASFurther deta ils of the DJI Phantom 2 Vision , and a PDF of the manual can be viewed

and downloaded here:

http://www.dji.com/product/phantom

- 2

- vision/spec



### General Features  Lightweight, multi

- functional integrated aircraft and camera

 Camera remote

- control by DJI VISION APP

 Range Extender increases Wi

- Fi distance to 300m

 Anti

- vibration camera platform with single axis stabilisation

 Low

- voltage protection

 Virtual Radar aircraft locator on mobile device

 Range of camera tilt options

 Multiple, continuous and timed capture options

 HD Video Recor ding (1080/p30 or 1080/60i)

 RAW and JPEG picture formats



### Aircraft Battery

5200mAh LiPo

Weight (Battery & Propellers Included)

1160g

Hover 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)

Diagonal Length

350mm

Tilting Range Of Gimbal

0°

- 60°



### Transmitter Operating Frequency

5.728GHz

- 5.8GHz

Communication Distance (Open Area)

CE: 300m; FCC: 500m

Receiver Sensitivity (1%PER)

- 93dBm

Transmitter Power

CE: 25mw; FCC: 125mw

Working Voltage

80 mA@6V

Battery4 AA Batteries



### Camera Resolution

14 Megapixels

FOV

120°/ 110°/ 85°

Sensor Size

1/2.3"

Functionality

 Support of multi

- capture, continuous capture and timed capture

 Support of HD Recording (1080/p30 or 1080/60i)

 Supports of both RAW and JPEG picture format



### Range Extender Operating Frequency

2412

- 2462MHz

Communication Distance (Open Area)

300m

Transmitter Power

<=17dBm

Power Consumption

1.5W



### DJI VISION App System Requirement Of Mobile Device

iOS version 6.1 or above/ Android system version 4.0 or above

Mobile Device Support

 iOS recommended: iPhone 4s, iPhone 5, iPhone 5s, iPhone 6, iPhone 6 Plus, iPod touch 5 (available but not recommended: iPad 3 , iPad 4, iPad mini)

 Android recommended: Samsung Galaxy S3, S4, Note 2, Note 3 or phones of similar configuration