September 14, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 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 91.109 ; 14 CFR 91.119(c) ; 14 CFR 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: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “ Reform Act” ) and 14 CFR Part 11, Chad Jackson, DBA “ C&S Photography, ” operator of the DJI Phantom 3 Advanced Unmanne d Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ( “ FARs ” ) to allow commercial operation of designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and newsgathering. 3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority. 4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation. 6. Training to persons individually or belonging to both private and/or public organizations to increase awareness and improve safety for current and future UAS operations within the NAS. As described fully below, the requested exemption would permit the operation of designated UAS as set forth in this document under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase public awa

reness of UAS operations and enhance safety to aid in fulfilling the Secretary of Transportation’ s (the FAA Administrator’ s) responsibilities to “ ....establish requirements for the safe operation of such aircraft systems in the national airspace system. ”The name and address of the applicant is:

Chad Jackson, DBA “ C&S Photography” Ph: 334.618.8239 Email: cjackson1117@sbcglobal.net Address: 117 Timbers Dr., Dothan, AL 36301 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 91.109 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) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b) Chad Jackson, DBA “ C&S Photography” , will operate one or more of the following model UAS: DJIPhantom 3 Advanced (with the following UAS specifications)



### Aircraft **Weight (including battery and propellers)**



### 1280 g **Diagonal size (including propellers)**  

### 590 mm **Max Ascent Speed** 

### 5 m/s **Max Descent Speed** 

### 3 m/s**Hover Accuracy**

 

### Vertical: +/

- 0.1 m (when Vision Positioning is active) or +/

- 0.5 m
 

### Horizontal: +/

- 1.5 m **Max Speed** 

### 16 m/s (ATTI mode, no wind) **Max Altitude Above Sea Level** 

### 6000 m **Operating Temperature**  

### 0°C to 40°C **GPS Mode** 

### GPS/GL ONASS

**Camera Sensor** 



### Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)
**Lens** 

### FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ **ISO Range** 

### 100

- 3200 (video) 100

- 1600 (photo) **Shutter Speed** 

### 8s

- 1/8000s **Image Max Size** 

### 4000 x 3000 **Still Photography Modes**

 

### Single Shot
 

### Burst Shooting: 3/5/7 shots 

### Auto Exposure Bracketing (AEB): 3/5
 

### Bracketed Frames at 0.7EV Bias
 

### Time

- lapse

Given the small size of the UAS in scope and the controlled environment provided, the proposed operations will adhere to the Reform Act’ s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly, the applicant graciously requests that the FAA grant the requested exemption. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircr aft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with battery and camera. 2. The UAS, depending on the model in operation, will have a maximum operating speed of no more than 45 MPH. 3. Flights will be operated within line of sight of the Pilot in Command (PIC) and /or Visual Observer (VO). 4. Maximum flight time for each operational flight will be depending on the UAS model in operation, but will not exceed 20 minutes. Flights will be terminated at 20 % battery power reserve or 10 minutes of flight time whichever occurs first. 5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 6. Minimum crew for each ope ration will consist of the UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate, Camera Operator (CO). 7. The UAS pilot will be a designated Pilot in Command (PIC) . The PIC will have logged a minimum of 20 hours on the d esignated UAS. 8. A safety briefing will be performed prior to each day’ s flights consisting of all the days ’ production activities. 9. All flight activities will be logged. 10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.11. The flights will occur in Class G airspace no closer than a 5 mile radius of the geographic

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport. 12. Flights will not be closer than a 5 mile radius of the geo graphic center/Airport. 13. The operator will file FAA Form 7711 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 14. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S. Department of Transportation required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved. 15. The PIC and VO will have been trained in operation of UAS and receive up to date information for the particular UAS to be operated. 16. The PIC and VO will be able to communicate by voice and/or radio at all times. 17. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations. 18. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have th e capability to return to a pre

- determined location within a designated location and land autonomously. 19. The UAS will have the capability to abort a flight in case of emergencies with an automated
“ Return Home ” and “ Land” function. 20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies such as low battery.
THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 C&S Photography submits that grant of this exemption application for use of the DJI Phant om 3 Advanced in precision aerial surveying, inspection, videography and photography will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of UAS ’ s into the national airspace system ( “NAS ” ) if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain UASs may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secreta ry is required to determine which types of 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 UAS ’ s size, weight, speed, 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)(1). If the Secretary determines that such vehicles “ may operate safely in the national airspace system, the Secret ary shall establish requirements for the safe operation of such aircraft in the national airspace system. ” Id. § 333(c). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes e xempting civil aircraft, as the term is defined under § 40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act ; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations ; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to UAS ’ s for aerial surveying, photography, inspection and videography. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay as these are services desperately needed in the Alabama area due to several large company expansion projects and the need to monitor their expansions effect on the local geographic area

. Grant of the exemptio n to C&S Photoraphy will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of UAS by public entities pursuant to Certificates of Authorization, with additional restrictions:

● All operation s to occur in Class G airspace

● Operations to avoid congested or populated areas, which are depicted in yellow on VFR C harts

● Operations to be conducted over private or controlled access P roperty

● Permission from land owner/controller required before commencing any flight

● Operations to occur during Visual Flight Rules Meteorological Conditions (VMC)

● Aircraft to remain within Visual Line of Sight (VLOS)
○ VLOS guaranteed with a cylinder of op eration around operator of 1⁄2 nautical miles (NM) ○ Cylinder walls may be expanded by additional observer’ s

● Operations to occur during daylight hours

● Above Ground Level (AGL) altitude to be restricted to 400 feet● All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline

azimuth of runway centerline measured from runway thresholds

● All required permissions and permits will be obtained from territorial, state, county or city jurisdict ions, including local law enforcement, fire, or other appropriate governmental agencies Operator Requirements C&S Photography respectfully proposes that operator requirements should take into account the characteristics of the particular UAS. Certain UAS s, such as the DJI Phantom 3 Advanced are characterized by a high degree of preprogrammed control and various built

- in technical capabilities that limit the potential for operation outside of the operating conditions set forth above. The DJI Phantom 3 Adv anced has a semiautonomous navigation and control system comprised of a Ground Control Station (GCS), GPS stabilization and autopilot system. In the case of unplanned events, the operator can allow the aircraft to follow the preprogrammed evasive maneuvers from the control unit or enable assisted steering for direct control. Preprogrammed maneuvers include initiation of holding at present position ; suspension of mission ; fly back to launch point; fly to point and hold ; abort mission and land; and emergency power cut off and land (Flight Termination System). Additional automated safety functions and safety enhancing features of the DJI Phantom 3 Advanced include the following:

● Detection of lost GPS signal will initiate a return to launch program, allowing the operator time to take control if necessary.

● The GCS produces an audible message of the battery level every 1560 Seconds (this can be adjusted). At 10.2V (this can be adjusted) overall pack voltage the aircraft will automatically land.

● Onboard failsafe limits aircraft descent speed to a maximum of approximately 5 m/s .

● The aircraft, weighing less than 4 lbs, fully loaded, is constructed of high impact plastic or similar material which is intended to absorb impact energy.

● The motor is drive n by a pulse width modulated signal, not an analog signal. In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to allow commercial operations of a small unmanned vehicle conducting aerial imaging, photography, videography, inspection and surveying. Approval of the exemption allowing commercial operations of the Iris+ for aerial imaging, photography, videography, inspection and surveying work will enhance safety by reducing risk. Conventional aerial operations, using jet or piston powered aircraft present risks associated with vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs, carry large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey location. In contr ast, a DJI Phantom 3 Advanced weighing less than 4 lbs and powered by batteries eliminates a portion of that risk given the reduced mass and lack of combustible fuel carried on board. The DJ I Phantom 3 Advanced is carried to the survey location, not flown there. The DJ I Phantom 3 Adavancedwill carry no passengers or crew and, therefore, will not expose any individuals to the risks associated

with manned aircraft flights. The operation of the DJ I Phantom 3 Advanced, weighing less than 4 lbs, for aerial imaging, photography, videography, inspection and surveying in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting Aeris Imaging from the requirements of Part 21. The DJIPhantom 3 Advanced’ s satisfaction of the criteria set forth in Section 333 of the Reform Act

— size, weight, speed, operating capabilities, lack of proximity to airports and populated areas, operation within visual line o f sight, and national security

— and its showing of an equivalent level of safety as it may relate to the requirement for a pilot’ s license, provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of the DJ I Phantom 3 Advanced in the commercial precision video and imaging business. Sincerely, Chad Jackson C&S Photography 117 Timbers Dr Dothan, AL 36301 334

- 618

- 8239