### Photo Flight LLC 2044 Utley Rd

– Suite 1 Flint, MI 48532 

# (810) 309

- 9160

April 9, 2015

U. S. Department of Transportation Docket Management System
1200 New Jers ey Ave. SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam,

This petition is being submitted on our own behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Photo Flight LLC , a Michigan based lim ited liability company operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of ou r sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The reques ted exemption would permit Photo Flight LLC to pursue its commercia l interests in providing services to consumers intere sted aerial data capture using small advanc ed sUAS in the following areas:

 Real Estate Photography

 Agricultural Surveying

 Special Events Photography

Photo Flight LLC states that all sUAS flights will occur over private or controlled access property
and will only do so with the property owne r's prior consent and knowledge and n ot before a thorough inspection and survey of the property.

P hoto Flight LLC sUAS operators have completed a minimum of 80 hours of flight and training including at least 40 hours indoor f light training regarding safety

, maintenance

, calibrations

, maneuvering and controls with an additional 40 hours minimum of outdoor flight training and practice before being permitted to fly commercially. All sUAS operators must pass a physical and be in good sound medical and mental health.P hoto Flight LLC is requesting exemption from the following regulations:

 14 C.F.R. Part 21

 14 C.F.R. 45.23 (b)

 14 C.F.R. 61.113(a) and (b)

 14 C.F.R. 91.7 (a)

 14 C.F.R. 91.9 (b) (2)

 14 C.F.R. 91.109

 14 C.F.R

. 91.119

 14 C.F.R. 91.121

 14 C.F.R. 91.151(a)

 14 C.F.R. 91.203 (a) & (b)

 14 C.F.R. 91.205 (b)

 14 C.F.R. 91.215

 14 C.F.R. (91.401

- 91.417)

Unmanned Aircraft System

sUAS are a feasible method to obtain information of agricultural cropland to determine opt imum inputs that result in cost savings to farmers, yield security, and reduce environmental impact of
excess fertil izers and chemicals in the soil. Additionally Aer ial Real Estate Photography is growing in popularity and is a chosen method for highlighting and showing overviews of property for potential sale.

We are petitioning for exemption to enable Photo Flight LLC to operate a DJI Phantom 2 Vision
Plus multi

- rotor equipped with a three

- axis gimbaled camera, a DJI Inspire 1 multi

- rotor equipped
with a three

- axis gimbaled camera, and a BLADE 350 QX3 AP multi

- rotor equipped with a three

axis gimbaled camera . These sUAS all weigh less than 25 lbs. , have a built

- in capability to limit the height it flies above the ground and to limit the radius of the dis tance it flies from the operator. Each system also has the failsafe function of the autopilot Return Home feature. This feature can be activated manually by the sUAV operator and is activated automatically if
communication between the Main Controller and the transmitter is lost

. Once activated either manually or by a transmitter communication error, t he system will automatically trigger Return to
Home and the sUAS will land safely near the GPS coordinates in which it raised from.

Safety is of the top most concern at Photo Flight LLC . We have implemented policy and procedures to ensure safe operations. T he following are some of the basic safety rules and procedures in place:

 All sUAS equipment has f ir mware coded flight restrictions limiting above ground flight to 115 meters (approximately 377 feet) above ground and 200 meters (approximately 656 feet) Geo Fence restricting the sUAS to travel no further than 200 meters from the sUAS operator.

 Once a week Accelerometer and Pressure sensor calibrations will be done in a controlled
envi ronment.

 Once a month calibrations will be monitored through diagnostics software and firmware’s verified and updated if necessary.

 Any updated firmware will be fully tested in a controlled environment for at least 1 hour worth of flight time before being flown commercially.

 No flights will be pe rmitted after 30 minutes before sunset and sUAS will never be flown in the path of any aircraft.

 Before each flight a compass calibration will be done on site along with preflight mechanical inspections including battery levels in the sUAS a nd transmitter. Before each flight a property survey will be done checking for power lines, antennas, trees,

and any overhead objects. Wind conditions will be monitored and al so be factored before flying.

 Only a fully charged and balanced battery is to be used at each take off.

 While in flight either the sUAS operator or secondary visual observer must be able to see the indicator LED light affixed to the sUAS

.

 No flight will ever exceed 8 minutes. A t the beginning of each flight a timer will be
activated. At 7 minutes the timer will go off alerting the sUAS operator to begin to land. If a battery alert is indicated on the always visible LED prior to the 7 minute timer expiration the sUAS is to be landed immediately and the battery recycled or discarded safely as it proved to be defective.

The above spec ifications and safety precautions meet and exceed standards listed below, some
deriv ed in accordance with the Model Aircraft Operating Standards:

 The petitioner will only operate its sUAS in line of sight of the sUAS operator and secondary visual observer and will operate at sites that are a 'sufficient distan ce' from populated areas within the sterile area described in the operator’s manual. Such operations will insure that the sUAS will "not create a hazard to users of the national airspace system or the public."

 Maximum flight time for each operational flight will be 8 minutes.

 Flights will be terminated at 25% battery powe r reserve should that occur prior to the 8
minute limit.

 The sUAV will be programmed so that it will be operated at an altitude of no more than
378 feet AGL.

 Minimum crew for each operation will consist of the sUAS Operator and a second Visual
Observer. At no time will the sUAS pilot or the secondary observer be out of line of sight
from the sUAS

.

 T he sUAS operated by the petitioner weighs less than 2 5 pounds, including the payload (i.e. camera, lens, and gimbal).

 The sUAS will operate at speeds of no more than 55 knots.

 Given the small size of the sUAS and the restricted sterile environment with in which they will operate, our sUAS operations adhere to the Reform Act's safety requirements.

We respectfully request exemption under Section 333 to enable Photo Flight LLC to operate safe,
low

- risk commercial sUAV operations for the activities stated. Photo Flight LLC at all tim es will respect the space and privacy of citizens and property while keeping our skies safe.

Sincerely,

Scott T. Tabor CEO / Photo Flight LLC
2044 UTLEY RD SUITE 1 Flint, MI 48532 (810) 309

- 9160