Matt Burchfield

Tranquility Ace Aerial Photography, LLC

1929 Leesburg Dr

Clover, SC 29710

May 19, 2015

U.S. Department of Transportation Docket

Management System 1200 New Jersey Ave., SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: 1) Inspire 

1 Safety Guidelines 2) Inspire 1 Release Notes 

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the 

matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory 

Docket No. FAA–2014–0508 in the matter of the petition of ADVANCED AVIATION 

SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in 

the matter of the petition of FLYING CAM INC 

Dear Sir or Madam:

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, I, Matt Burchfield, 

request exemption from the following sections of Title 14, Code of Federal Regulations §§ 

61.113(a). 61.113(b). 91.119(c). 91.121. 91.151(a). 91.405(a). 91.407(a)(1). 91.409 (a)(1). 

91.409(a)(2). 91.417(a) & (b). 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial 

photography, structural inspections of bridges, pipelines, well and cell towers, real estate 

marketing and surveys and other flight operations that could be performed safely and more 

cost effectively with the use of small UAS at low altitude within the U.S. national airspace 

system as compared to a manned aircraft. Operations will be performed only at the request of 

and with the authorization and permission of clients or their authorized agents in order to 

facilitate commerce and raise awareness of the beneficial uses of small unmanned air 

systems. So long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. The conditions 

identified and proposed by, Matt Burchfield, are drawn from references 13. 
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The FARs 

I, Matt Burchfield, request exemption from the above mentioned FARs for the following 

reasons. 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command. 

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, 

however I can achieve an equivalent level of safety as achieved by current regulations 

because my UAS does not carry any pilots or passengers. While helpful, a pilots’ license 

will not ensure remote control piloting skills. The risks of operating a UAS are far less 

than the risk levels inherent in the commercial activities outlined in 14 CFR part61,et 

seq., I requests an exemption from §61.113 Private Pilot Privileges and Limitations.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted 

closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to 

essential persons, or objects that would not be possible without additional relief. The 

petitioner requests modification, waiver or exemption and clarification concerning the terms 

“congested areas” and “densely populated”. I, Matt Burchfield, request waiver for this 

condition to allow reasonable and responsible operations with safety as my main concern in 

areas of subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable 

since the UAS does not have an altimeter and instead utilizes electronic GPS with a 

barometric sensor for altitude information. 

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) 

prior relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS 

specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR 

conditions. The UAS provides battery power remaining in percent to the PIC. The UA 

batteries provide approximately 25 minutes of powered flight. Information provided in the 

operating documents discusses procedures regarding remaining battery power management. 

Those documents contain a condition in which the PIC will initiate a landing procedure when 

battery remaining reaches a specified level. Given the limitations on proposed operations and 

the location of those proposed operations, The FAA found that a reduced minimum power 

reserve for flight in daytime VFR conditions was reasonable. 91.405(a). 91.407(a)(1). 91.409 

(a)(1) & (2). 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), I, 

Matt Burchfield, propose to inspect and ensure that the UAS is in a condition for safe flight 

in accordance with the operating documents. The FAA found that adherence to the 

petitioner’s operating documents and the conditions and limitations specified, describing the 

requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that 

safety would not be adversely affected. 

The UAS 
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DJI Inspire 1 Quad Manufacturer: DJI Model: Inspire 1 T600 Weight: 2935 g / 6.47 

Pounds Passenger Capacity: 0 (unmanned) Size (dimensions): 438x451x301 mm 

(17.24x17.76x11.85 inches) Max Speed: 22 mps (72.18 fps / 49.21 mph) Max Flight 

Time: 18-25 mins Max Ceiling (software limited): 400 ft AGL Operations: Line of Sight 

Controller: Dedicated Commercial Controller with 2 km maximum rated operating 

distance. DJI Vision Positioning is a positioning system that uses ultrasonic and image 

data to help the aircraft identify its current position. With the help of Vision Positioning, 

the Inspire 1 can hover in place more precisely and fly indoors or in other environments 

where there is no GPS signal available. The main components of DJI Vision Positioning 

are located on the bottom of the Inspire 1, including two sonar sensors and one 

monocular camera. (Inspire 1 User Manual v1.2, 2015)

It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with 

global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled 

primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information 

is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery 

level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera 

angle. It has fail safe modes of operation for either loss of RC or GPS signal. Altitude can be limited 

by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life 

limits flight times to approximately 18 minutes. The onboard flight controller will warn the pilot via 

telemetry and external lighting cues before reaching a low battery state. An automatic termination of 

flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated 

that flights will usually last less than 10 minutes. More information is available in attachment 

1. 

Risk mitigation 

I, Matt Burchfield, have reviewed FAA exemptions reference’s 13 Conditions and 

Limitations section and believe that the procedures specified therein are reasonable and 

will be utilized in order to manage and mitigate risk and ensure public safety. 

A preflight checklist will be developed and employed to ensure that the UAS’s 

airworthiness will be verified before launch. Airworthiness will be maintained by 

performance of routine inspections before each flight, maintaining flight and maintenance 

logs to record time on failure prone components. 

I, Matt Burchfield, request that in a manner similar to reference 3, be allowed to operate 

within 5 miles of an airport provided that. 

“The UA may not operate in Class B, C, or D airspace without written approval from 

the FAA. The UA may not operate within 5 nautical miles of the geographic center of a 

non towered airport as denoted on a current FAA published aeronautical chart unless a 

letter of agreement with that airport’s management is obtained, and the operation is 
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conducted in accordance with a NOTAM as required by the operator’s COA. The letter 

of agreement with the airport management must be made available to the 

Administrator upon request.” 

Operations within 5 miles of an airport are not anticipated to be routine but I am requesting a 

mechanism to facilitate such activities without requesting a new and separate exemption(s) 

should the need arise. Operations within class B airspace are not requested due to the lack of 

mode C transponder. 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft of 

greater proportions, carrying a crew and flammable fuel. 

In regards to performing inspections of bridges, towers, and natural gas pipelines the UAS 

will minimize the risk to persons attempting to climb these structures and photograph 

problem areas. It will provide a way for companies to have their engineers review 

photographs and provide additional safety to the general public in regards to towers failing or 

natural gas pipelines having structural issues. Many of the natural gas pipelines in our area 

travel in areas that are hard to reach by vehicle or foot and if an area is suspected of having 

problems the UAS can reach it to make an assessment easier and safer. 

I, Matt Burchfield, will also make the UAS and myself available to local volunteer 

organizations (for no charge) such as fire departments, local law enforcement, etc., to 

perform search and rescue operations, or other similar events as directed by authorities. 

In addition the use of the UAS in order to facilitate commerce could lead to economic 

growth. Operations for this petition will enable service for property owners or their 

designees seeking an enhanced perspective for characteristics, amenities, and benefits of 

their desired photographic subjects that cannot be displayed through ground level 

photography. Aerial photography is a valuable marketing tool that can lead to increased 

commerce and enhance my personal photography. A visual observer will be utilized at all 

times that the UAS is performing duties for compensation and the PIC will hold a Private 

Pilots license. 

Liability insurance will be obtained commensurate with the granting of this request 

for exemption. 

Flight data including UAS flight time, Control Unit operation time, incident, and details will 

be recorded for each flight and made available to the FAA at any time needed. Any 

deviations from normal operations will also be recorded and made available to FAA. 

Conclusion 
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I, Matt Burchfield, am requesting this exemption for the purposes of aerial photography of 

real estate, bridge inspections, land surveying, pipeline inspections, tower inspections, and 

other flight operations. The reason for such a general and broad based request is that I, Matt 

Burchfield, wish to utilize a business strategy in order to capitalize on opportunities as they 

may arise in the future without the long turnaround time associated with additional 

exemptions. My business model is based on the idea of offering small UAS services to 

individuals or companies who wish to employ these services as a safe, effective, and legal 

option to enhance their business or prevent structural disasters that may influence the general 

public or individuals. 

My own research shows an upward demand for these services that currently exists in the 

real estate market, natural gas market and other markets are just beginning to realize the 

need for such services. 

Several people are offering services such as the above in my area but I have refrained 

for pursuing commercial use of my UAS until I can properly be authorized by the FAA. 

Thank you for your time and attention in this most important endeavor.

In His Lovingkindness,

Matt Burchfield

Tranquility Ace Aerial Photography, LLC