Aerial Perspective Northwest 

Owner and operator: Larry Haffner 

35708 S.E. Hurlburt Rd. 

Corbett, Oregon 97019 

Office: 503 695 5644 

Cell: 503 705 3781 

rn 

U.S. Department of Transportation 

Docket Management System 

1200 New. Jersey Ave. SE Rm. W12-140 

Washington, DC 20590-0001 

Dear Sirs, 

January 5, 2016 

Attached is a copy of my original petition submitted September 13, 2015 

Also: 

Attached a copy of my assigned N number which I understand is required in order to approve my 

application for Sec 333 exemption. 

Attached are copies of my license, physical and Biennial flight review performed within the last two 

months. 

Please expedite this application if possible and advise if you expect any possible delay. 

Respectfully, 

Larry Haffner 
t 

Aenal Perspective Northwest 

Owner and operator: Larry Haffner 

35708 S. E. Hurlburt Road 

Corbett, Oregon 97019 

Office: 503 695 5644 

Cell: 503 705 3781 

larryapnw@gmai1.'6m 

U.S Department of Transportation 

Docket Management System 

1200 New Jersey Ave. , SE Rm. 

W12-140 

Washington, DC 20590-0001 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments 1) 3DRobotics Iris+ User Manual vA 9 September 2014 

2) 3DRobotics Iris+ Flight Checklist Published 2014 

September 13 2015 

3) Overview of business intent, qualifications, and specifications 

References 1) FAA Exemption No 11 138 Regulatory Docket No. FAA-2014-0481 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 FAA-2014-0355 in 

the matter of the petition of FLYING CAM INC 

Dear S1r or Madam 

In accordance with the FAA s Guidelines for Subm1tt1ng a Petitton for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012 I Larry Haffner, referred to 

hereafter as the petitioner request exemption from the following sections of Title 14, 

Code of Federal Regulations 

61. 113(a). 61113(b) 91.119(c) 91121 91 151(a 91 .405(a). 91 .407(a)(1) 91.409 

(a)(1J 91.409(a)(2). 91.417(a) & (b) 

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

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

photography cinematography videography mapptng crop surveying inspections and 

other fltght operations that could be performed safely and more cost effectively with the 

use of small UAS at low altitude (less than 200 feet) withtn the U S nat onal a1rspace system as 

compared to a manned aircraft. Operations will be performed only at the request of and with the 

author zat on and permission of clients or their authonzed agents 1n order to facilitate 

commerce and raise awareness of the benefictal uses of small unmanned air systems 

So long as such operat1ons are conducted within and under the cond tions outlined 

1 
• herem or as may be established by the FAA as requ red by Sect on 333 The conditions 

1dent1 1ed and proposed by the petitioner are drawn from references 1 '3. 

The FARs 

The petitioner seeks exemption from the above ment1oned FARs for the followmg 

reasons 

61 1 3 a) & (b) The petitioner requests reltef 1n order to fac litate the tllizat1on of p1lots 

who hold a PRIVATE PILOT (or greater) certificate Any pilots opera 1ng under this 

exemption would be required to comply w1th any cond1t1ons as set forth and 1n a similar 

fashion to the previously granted exempttons 

91 .119(c) As discussed in Exemption 111 38 (DOUGLAS TRUDEAU) operations 

conduc e closer than 500 feet to the ground may requtre that the UA be operated 

closer t an 500 feet to essential persons or obJects that wou d not be poss ble without 

add1t o a relief. The petitioner requests modif1cat1on wa1ver or exemption and 

clanf catton concerning the terms "congested areas and densely populated The 

petitioner requests waiver for this condition to allow reasonable and responstble 

operat1 ons m areas of subdivisions and neighborhoods if required 

91.121 As discussed in Exemption 11 138 (DOUGLAS RUDEAU) 1s 1nappl1cable s1nce 

the UAS does not have an altimeter and instead ut lizes elect on1c GPS w1th a 

barometr c sensor for altitude 1nformat1on above takeoff 

91.151 (a) As discussed in Exemption 11 136 (ADVANCED AVIATION SOLUTIONS 

LLC) pnor relief has been granted for manned atrcraft to operate at less than the 

prescr bed mmimums. including Exemption Nos 2689 57 45 and 10650. In addition 

s1m11ar UAS-specific relief has been granted m Exemption Nos 8811 10808 and 10673 

for dayt me VFR conditions The UAS prov1des ba tery power remaming 1n voltage to 

the P C The UA batteries provide approximately 15 minutes of powe ed fl ight. 

lnformat on provided in the operating documents discusses procedures regarding 

remam1ng battery power management. Those documents conta1n a cond1t on in which 

the PIC w1 ll inttiate a landing procedure when battery remaining reaches a specified 

level. G ven the limitations on proposed operations and the location of those proposed 

operat ons The FAA found that a reduced m ntmum 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 m Exemption 

11138 (DOUGLAS TRUDEAU) The petitioner proposes to mspect and ensure that the 

UAS IS in a condition for safe flight 1n accordance wtth the operating documents The 

FAA found that adherence to the petitioner s operat1ng documents and the cond1t1ons 

and 11 at1ons specified describing the requ1rements for ma ntenance inspectton and 

record eepmg were sufficient to ensure that safet wou d not be adve sely affected 

The UAS 

The 3DRobotJcs Iris + is a h1ghly successful consumer grade small rotorcraft 1n the quadcopter 

configuration with an advertised weight of less than 4 3 pounds Destgned pr marily to carry aloft a 

high defin1t1on camera It has an advert sed max1mum speed of less than 33 knots (15m/s) and a 

max1mum cl mb rate of less than 1200 feet per mmute (6 m/s). It is powered by four electnc motors 

w1th a distance between motors of less than "6 inches ) It utilizes ar mternal 1nert1al measunng •. mit 

IMU\ w1th integrated barometric sensor augmented w1th global pos1tion1ng system (GPS) to 

mamtain ts geospatial orientation and posttion It 1s controlled primanly through an FCC certified 

rad1o control (RC) unit. Real time video and telemetry mformat1on IS transmitted back to a ground 

2 
control station allowing the operator and/or PIC to mon1tor battery level GPS signal strength. 

altitude (AGL) distance from PIC camera imagery , and control camera angle It has failsafe modes 

of operat1on for e1ther loss of RC or GPS s1gnal. Altitude can be limited by the onboard flight 

controller and max1mum altitude can be preprogrammed by the PIC. Battery life l1m1ts flight t1mes to 

approximately 15 mmutes. The onboard flight controller will warn the pilot via telemetry and external 

light1ng cues before reaching a low battery state. An automatic termmation 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 8 mmutes. More information is available 1n attachment 1 or 

rtJQ •WW\111 · 

Risk mitigatio n 

The petitioner has rev1ewed FAA exemptions reference s 1-3 Conditions and L1mitat1ons 

sect1on and believes that the procedures specified there1n are reasonable and will be utilized in 

order to manage and mit1gate r sk and ensure public safety. A preflight checklist will be utilized to 

ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintamed by 

performance of routme inspections before each flight, maintaming flight and matntenance logs to 

record time on failure-prone components. This 1ncludes but is not lim1ted to. security of legs, motor 

mounts, prop hubs. prop condition. Battery secunty latch, camera mount and g1mble mount. 

Battenes will be checked for full charge before takeoff. 

The petitioner requests that in a manner s1milar to reference 3 he be allowed to operate 

within 5 miles of an a1rport provided that· 

"The UA may not operate 1n Class B. C or D atrspace Without written approval from 

the FAA. The UA may not operate within 5 naut1cal miles of the geographic center of a 

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

letter of agreement w1th that airport's management is obtained and the operation is 

conducted in accordance with a NOT AM as required by the operator's COA. The letter of 

agreement w1th the a1rport management must be made available to the Administrator upon 

request." 

However. the pet1t1oner requests that the UAV may be operated w1th1n 5 miles of a towered or 

non-towered a1rport without a s1gned agreement as long as the UAV mainta1ns a minimum of 500 

foot lateral distance from the a1rport boundary with one mile distance from the boundary on a 

prectston approach AND rema1ns below 100 ft AGL. 

Operat1ons within 5 miles of an airport are not anticipated to be routine but the petitioner 

is requesting a mechanism to facilitate such activities without requesting a new and 

separate exemption(s) should the need arise Operations within class 8 airspace are 

not requested due to the lack of mode C transponder. 

Public interest 

Use o the UAS in l1eu of a manned a1rcraft would enhance safety and reduce the envtronmental 

1mpact as compared to Similar operations conducted w1th manned aircraft of greater proportions, 

carrying a crew and flammable fuel. Additionally. 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 

videography/photography. Aerial photography is a valuable marketing tool that can I ad t 

increased commerce and enhance personal photography. Crop survey1ng applications could ead to 

decreased use of pesticides and fertilizer and conservation of water as well as increased crop 

yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, 

improve resultsand reduce risks The petitioner will provide clients with photographic data for these 

purposes on a 'for hire' basis acting as an independent contractor. UAV will remain within visual 

3 
} contact by the pilot or aVO at all times. A visual observer (VO) may utilize a dual radio, press to 

talk, for instant communication. One sentence voice commands will be pre briefed. Liability 

insurance will be obtained commensurate with the granting of this request fo exemption Flight data 

including UA flight time Control Unit operation t ncident ace de t and details conce n ng any 

deviations from normal ope a 1on I vailable FAA for use in collecting data regarding the 

use of UAS as par or this application This data may be submitted to FAA via traditional means e g 

COA Monthly Reports or other means as required 

Conclusion 

The pettioner is requesting this exemption for the purposes of aerial photography cinematography 

videography, mapping, crop surveying, inspections and other fl ight operations The reason for such 

a general and broad based request is that the petitioner wishes to utilize a business strategy of 

horizontal integration and maximize economies of scope in order to capitalize on opportunities as 

they may arise in the future w thout the long turnaround time associated with additional exemptions. 

The petitioner's business model is based on the idea of offering ad hoc small UAS services to 

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

enhance their business. The petitioners own market research shows pent up demand for these 

services currently exists The petitioner has identified municipal agencies, niversities, realtors and 

property managers would benefit from the operation requested in th s a plication The prima y 

purpose of seeking this exemption is to obtain the capability to offer those services while remaining 

in compliance. The petitioner has 49 years of experience in commercial aviation and many modes of 

parachuting with aerial photography as a hobby and holds an AIRLINE TRANSPORT PILO 

, s wei as a curre; third class me ica ertificate 

Respectfully submitted, 

{I' '4 1 1n 

'I" 

4 
REGISTRATION NOT TRANSFERABLE -- - - - - - ---- - ---

UNITED STATES OF AMERICA I This certificate 

DEPARTMENT OF TRANSPORTATION- FEDERAL AVIATION ADMINISTRATION must be in the airCERTIFICATE OF AIRCRAFT REGISTRATION craft when operated. 

NATIONALITY AND I AI

1

Rr<?M'T SERIAL NO. 

REGISTRATION MARKS N 62 80W 

MANUFACTURER AND MANUFACTURER 'S DESIGNATION OF 

3D ROBOTICS IRIS+ 

ICAO Aircraft Address Code: 52033142 

This certificate is 

issued for 

I HAFFNER LARRY G DBA registration purposes 

s AERIAL PERSPECTIVE NORTHWEST only and is not a 

s 3 5 708 5E HURLBURT RD certificate of title. 

u CORBETT OR 97019-9620 

The Federal Aviation 

E 

Administration does 

D 

not determine rights 

of ownership as 

T 

between private 

0 

persons. 

Individual 

It is certified that 0 the above described aircraft has been entered on the register of the Federal Aviation Administration, United States of America, in accordance with the Convention on 

lnternattonal CIVIl Avtatton dated December 7, 1944, and wtth Title 49, Umted States Code, US Departm1 

and regulations issued thereunder. 

November 24, 201 5 lrcr,r-/ ofTranspo~ DATE OF ISSUE .E~eral ~ja EXPIRATION DATE November 30, 2018 ADMINI~f(j,i ~::::· ";l(!ii\ ifill'is't1'8-. : .... 

AC Form 8050 3 ( 10/2010) Supersedes preVIOUS editions 

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U.S. Department 

of Transportation 

Federal Aviation 

Administrat ion • 

. 

. 

Civil Aviation Registry 

P.O. Box 25504 

Oklahoma City, OK 73125-0504 

Official Business 

Penalty for Private Use $300 

us POSTAG

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ZIP 73169 

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000140307

AC Form 8050-3 (1012010) Supersedes previous edition 62

TO: HAFFN ER LARRY G D BA 

35708 SE H URLBURT RD 

CORBETT OR 97019-9620 

iiilliiJ, JJ jiJi il'ii ju iiJI ji ij! I i 1/J Jii Iii ni / 11 ii
UNITED STATES OF AMERICA 

Department of Transportation 

Federal Aviation Administration 

EYEs ~-: 

lt ~;,y 

MEDICAL CERTIFICATE SECOND CLASS 

This certifies that (Full name and address): 

LARRY gail HAH""NER 

Must wear corrective lenses. 

Date of Examination 

FAA Fonn 8500-9 (3-12) Sup<n;edeo Prev;ou, Edition NSN: 0052.00.070-7002 
CONDITIONS OF FLIGHT NO. I NO. 

IINSTR. LDG. ••··----·--,-------,-1 - - ---,-, -----,-, -S-IM_U_LA_ T_E-:-- D--1 APPR. 

INSTR. 

I 

REMARKS, PROCEDURES, MANEUVERS 

I certify that the statements made by me on this form are true. 

PILOrS SIGNATU RE 
OINTS OF 

TURE & ARRIVAL 

TO 

PAGE TOTAL 

AMOUNT FORWARD 

TOTAL TO DATE 

AIRCRAFT CATEGORY 

AIRPLANE 

SEL 

AIRPLANE 

MEL 

GROUND 

TRAINER 

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