Professional Photography and Videography ∞ Providing safe, legal, ethical, quality service. 

### Loon Aerial Services UAV Photography/Videography 9032 N Cuff Road, Hayden ID 83835 loonaerial@gmail.com (208) 640

- 9130

U. S. Department of Transportation Docket Operat ions West Building Ground Floor Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

SUBJ: 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, Loon Aerial Services ( Anthony Woltz ), Owner of an Unmanned Aircraft System (UAS), h ereby applies for an exemption from t he listed Federal Aviation Regulations (FARs) to allow Loon Aerial Services to legally operate its DJI Phantom 3 UAS, so long as such operations are conducted within and under the conditions outlined herein and as may be established by the FAA as required b y section 333.
The proposed exemption would allow Loon Aerial Services to operate a small UAS under controlled conditions in FAA regulated airspace that is limited
, predetermined
, and controlled, for purposes of unmanned aerial photography and videograp hy for public, private, or commercial use including but not limited to golf courses, real estate, agriculture/livestock, land surveying, marketing for private businesses , construction site surveys, and search and rescue operations

. If the exemption is granted, Loon Aerial Services will conduct commercial UAS flights following all conditions set forth by the FAA Section 333 with emphasis on safety and operational requirements.
Proposed Operations of Loon Aerial Services UAS

 Aerial Video and Photography for public, private, or comm ercial use including but not limited to golf courses, real estate, agriculture/livestock, land surveying, marketing for private b usinesses and construction site surveys, and search and rescue operations

.Professional Photography and Videography ∞ Providing safe, legal, ethical, quality service.

Loon Aerial Services will follow all FAA UAS Safety Operating Guidelines including but not li mited to the following:

 The UAS will operate no more than 400 feet above ground level and within a radius of 1000 feet of Pilot in Command (PIC) and will not exceed 35mph.

 Operations will only occur during daytime conditions abiding by Visual Flight Rules (VFR) within Visual line of sight (VLOS) of the UAS pilots at all times.

 Obtain permission from the owner or representative of the owner to conduct operations

o If operations occur within 500 feet of any vessel, vehicle, or structure, a safety assessment wil l be conducted.

 Flight times will be limited to 10

- 15 minutes per flight. Allowing 25% of total battery to be used to safely land the UAS. This exceeds the manufacturer's recommended minimum battery level parameters for “return to home” function.

 DJI Phant om 3 utilizes Global Positioning System (GPS), which will automatically land (return to home) the UAS in any cases where Communication between PIC and craft is lost or the battery levels reach a critical level. DJI Phantom 3 can also be returned home

manua lly with the “return to home” button on controller.

 Contact Airports if operations are within a 5 mile radius. Advise Airports of all pertinent information including but not limited to: time of flight, flight duration, elevation of flight.

 Only operate UAS in safe weather conditions. Unsafe conditions include, but are not limited to high wind, poor visibility, low clouds or any conditions that may cause the pilot to lose VLOS or control of the UAS.
This will be achieved by:

o Obtaining and reviewing weather reports prior to flight

o Procedures for a mid

- flight abort in cases where weather or other factors cause conditions to become unsafe or dangerous.

 Only operate in controlled environment

o Will have procedures in place to identify and avoid any hazardous area s such as power lines, street lights, trees, airports, densely populated areas (yellow areas on VFR charts)

o Will have procedures in place to abort flights that have safety breaches or dangerous issues.

o Will always operate UAS with 2 people, with a designat ed “ V isual O bserver ” (VO) who will also keep constant Visual Contact with UAS along with PIC. All VOs will complete a company training program prior to fulfillin g that role.

o Will have policies that will clear the operational flight area of any non

- essential personnel.

 We will conduct extensive preflight inspections on the UAS, utilizi ng procedures that will check integrity of all operational parts including but not limited to: propellers, aircraft antenna, aircraft LED lights, remote buttons, control sticks, signal strength between craft and remote, signal strength of GPS, battery stre ngth.

 We will follow guidelines of 14 CFR 61.51(b) along with our own safety operation procedures.

o The PIC will have a minimum of 6 hours logged operating the craft before commercial use, along with over 10 hours operating UAS quadcopters in various condi tions and environments.Professional Photography and Videography ∞ Providing safe, legal, ethical, quality service. o With emphasis on safety, we will have training procedures that include emergency landing, evasive maneuvers and other possible dangerous scenarios such as yielding the right away to any airplane or helicopter that comes within 5 miles of the operating UAS.

Loon Aerial Services requests exemptions from the specific regulations outlined below and any additional regulations that may technically apply to the operation of the UAS for purposes of acquiring photos and videos which will promote local economic growth through employment and tax base.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of ai rworthiness certificates as required by FAR 91.203 (a) (1 ).
Given the size and limited operating area associated UAS, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 333 of the Reform Act. Fed eral Aviation Act (49 U.S.C.4470 1 (f)) and 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airpo rts and populated areas of the particular UAS.
In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, o r safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions of proposed UAS operations.
The UAS to be operated by Loon Aerial Services is less than 55lbs. f ully loaded , carries neither pilot, nor passengers, carries no explosive or flammable materials including combustible fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be controlled and monitored by both the pilot (PIC) and “Visual O bserver (VO)” as a secondary monitor for safety issues. These enhancements to current safety practices and regulations, which already apply to civil aircraft, provide a greater degree of safety to the public and property owners than conventional aircraft operation s conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.
Lastly, application of these same criteria demonstrates that there is no intrinsic credible threat to national security posed by the UAS, due to its size, speed of oper ation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 CFR 45.23(b) Display of marks; general and 45.29 Size of marks
These regulations provide that each aircraft must di splay "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display theProfessional Photography and Videography ∞ Providing safe, legal, ethical, quality service.

word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station.

The physical si ze of the UAS does not lend itself to markings of that magnitude and therefore any markings would not be visible from any distance. Loon Aerial Services aircraft will be marked appropriately with the largest font practical.

14 CFR 61.113(a) Private Pilot Privileges and Limitations: Pilot in Command

Loon Aerial Services requests an exemption from the private pilot privileges and limitations of 61.113 (a) & (b): Private Pilot Privileges and Limitations: The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. S ubparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. The UAS aircraft cannot carry passengers or property, therefore an exemption is needed.

14 CFR 91.7(a) Civil Aircraft Worthiness

Loon Aerial Services request an exemption from 91.7(a) which prohibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

Loon Aerial Services request an exempt ion from 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and given its size, this regulation is inapplicable. We believe an equivalent level of safety will be achiev ed by maintaining a safety/flight manual with the UAS ground station.

14 CFR 91.103 PIC to become familiar with specific information before each flight

Loon Aerial Services requests an exemption from 91.103, which requires a PIC to become familiar with sp ecific information before each flight, including information contained in the FAA approved Flight Manual on board the aircraft. As an FAA approved flight manual will not be provided for the UAS, an exemption will be needed.
The equivalent l evel of s afety will be achieved by fol l owing the DJI manufactures aircraft manual with comprehensive preflight checklist. Other comprehensive preflight information gathering and interpreting will be done by the PIC utilizing weather reports, webProfessional Photography and Videography ∞ Providing safe, legal, ethical, quality service.

based mapping (google ear th)
, battery requirements, and determining safe takeoff and landing areas. All pertinent information will be gathered and interpreted by PIC before any flights.

14 CFR 91.109 Flight Instruction

Loon Aerial Services requests an exemption from the 14 CFR 91.109(a) which provides that person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functional dual controls. UAS and remotely pil oted aircraft, by their design do not have fully functional dual controls. The control box communicates with the UAS through radio communications.
Equal levels of safety will be achieved based on the size and speed of UAS an equal level of safe training can be achieved without the “dual controls” because the UAS is unmanned and all essential personnel will be a safe distance away in the event of difficulties during the flight.

14 CFR 91.119 Minimum safe altitudes

Loon Aerial Services requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non

- co ngested areas. See 14 CFR 91.119(c). Section 91.119(d)(1) allows for a hazard to persons helicopter complies with any routes or altitudes specifically prescribed for helicopters . Current FAA guidance only allows UAS to operate under 400 feet AGL

.

14 CFR 91.12 1 Maintain cruising altitude or flight level by reference to an altimeter

Loon Aerial Services requests an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimete r that is set to the elevation of the departure airport or barometric pressure. An exemption is required because the UAS does not have a barometric altimeter, but the Phantom 3 software has a GPS altitude meter display. PIC will use display to constantly m onitor altitude during the flight.

14 CFR 91.151(a)

Loon Aerial Services requests an exemption from 14 CFR 91.151(a) fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person may begin a flight in an airplane under VFR condition s unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed (1) During the day, to fly after that for at least 30 minutes or (2) At night, to fly after t hat for atProfessional Photography and Videography ∞ Providing safe, legal, ethical, quality service.

least 45 minutes. The battery powering the Phantom 3 UAS provides approximately 20 minutes of powered flight. An exemption from the 30 minute reserve requirement in 14 CFR 91.151 is therefore required.
Equal levels of safety can be achieved by limiting flight times to approximately 10

- 15 minutes or until 25% of battery life remains, whichever comes first. This is more than enough battery power to achieve a safe landing.

14 CFR 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a)&(b) Maintenance and inspection standards in reference to 14 C.F.R. Part 43.

Loon Aerial Services requests exemptions from these regulations because Part 43 and these sections apply only to aircraft with an airworthiness certificate, which the UAS will not have.

Loon Aerial S ervices will achieve an equivalent level of safety because maintenance and inspections will be performed in accordance with the DJI Phantom 3 Aircraft Operations Manual.
The operator will ensure that the UAS is in working order prior to initiating flight, perform all required maintenance, and keep a comprehensive log of any maintenance performed on UAS.
The UAS small size, carrying capacity, and the fact that flight operations will only take place in controlled areas for limited periods of time, create less risk than the same factors associated with conventional fixed

- wing aircraft and rotorcraft performing the same operation.

Public Interest

The current a erial photography and v ideography uses either fixed wing aircraft or helicopters which have expensive op erating costs, the use of large heavy aircrafts, and manned flight operation introduces certain elements of risk for the public and pilot safety. Along with the additional risk associated with manned flight, the cost to small business owners is often expen sive. By granting Loon Aerial Services an exemption, we will be able to provide photography and videography at a lower cost. This will stimulate local commerce by giving the small business owner access to high quality promotional media and add on services to their own services, while also minimizing safety risks by utilizing a small unmanned UAS.

UAS Overview : Loon Aerial Services will operate the DJI Phantom 3 Professional

 Dimensions

o Size

- 40.36cm x 40.36cm x 19.05 x or 16inch x 16inch x 7.5inch

o Weight

- 1280g total or 2lbs 13oz totalProfessional Photography and Videography ∞ Providing safe, legal, ethical, quality service.

 Speed

o Under still air maximum speed is no more than 16m/s or 35mph with a cruising speed of 11m/s or 25mph

 Motors

o 4 motors total

o Motor model DJI 3510

 Power

o 4480mAh 4s LiPo Lithium Polymer Battery

 Propellers

o Model DJI 1345

 Remote Controller

o DJI issued C3 remoter controller

o Operating frequency

- 2.400GHz

- 2.483GHz

o Live Video frequency

- 2.4GHz ISM (max range

- 1.2 miles)

 Operation Parameters

o Loon Aerial Services will operate the UAS with visual line of sight within a closed off pre

- determined area; With authorization of the property owner or representative.

DJI Phantom 3 GENERAL FEATURES

 Ready to fly

 Precision flight and stable hovering

 GPS/GLONASS positioning and auto return home

 FAA no

- fly zones locked out via DJI installed software

 Onscreen real

- time flight parameters

o High Definition 4k camera

o 3 Axis camera stabilization

o Adobe lens profile support

o Album synchronization

o DJI VISION APP

- System requirement of Mobile Device: iOS version 6.0 or above/ Android system version 4.0 or above

 CAMERA

o Operating Environment Temperature

- 0 degrees C to 40 degrees C

o FOV

- 94 degrees/85degrees

o Sensor Size

- 1/ 2.3”

o Max Resolution

- 4096x2162p @24/25 fps

 TRANSMITTER

o Communication Distance (open area)

– CE: 2000m; FCC: 2000m

o Transmitter Power

- CE: 16dBm; FCC: 20dBm

o Operating Frequency

- 2.400 GHz

- 2.483 GHz

o Receiver Sensitivity (1%PER) :

- 101dBm +/

- 2dBmProfessional Photography and Videography ∞ Providing safe, legal, ethical, quality service. o Battery

- 6000 mAh LiPo 2s

o Working Voltage

- 1.2A @ 7.4V

Conclusion
The approval of this application presents no national security issues. Due to the small size of the unmanned UAS and the controlled environment, all proposed operations will meet or exceed the Reform Act’s safety requirements. Regarding the level of safety surrounding pr oposed operations and the public/economic benefit, the grant of the requested exemption is in the public interest for the following reasons: reduction in environmental impacts, including but not limited to reduced emissions and noise. For this reason, Loon Aerial Services requests that the FAA grant the requested exemption with minimum delay.

Manuals and Specifications:

 DJI Phantom 3 Professional User Manual

o http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manu al_v1.2_en.pdf
I would like to thank you for your consideration in granting the exemptions mentioned in this document. If additional information is required or if you have any questions
, please contact Anthony Woltz
, own er of Loon Aerial Services
, at 208

- 640

- 9130 or loonaerial@gmail.com

.

Respectfu lly
,

Anthony D. Woltz