Monday, August 10, 2015

U.S. DepartmentofTransportation Docket Management System 1200 NewJersey Avenue SE Washington, D.C. 20590

Submitted by: Soaring View, LLC. 4030 S. Wapakoneta Rd. Lima, Ohio 45806 Allen County (419) 227
.7653 Marla K. Bolen (member) Ashley D. Bolen (member) MichaelW. Schoonover (member) " soaringview@gmail.com

RE: EXEMPTION REQUEST SECTION 

### 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012
Scope: Enhance and augment real estate listings, construction, architecture, agriculture monitoring, inspections, insurance, marketing, surveying/mapping, sporting events, special events, festivals, weddings, wildlife/nature preservation and conservation, search and rescue, conducting aerial videography and photography by usingthe DJI Phantom 2 Vision+, OJI Phantom 3 Professional, DJI Inspire 1. UAV DJI Phantom 2 Vision+, Phantom 3 Professional, and DJIInspire 1

lofSThe DJI Phantom 2 Vision+, Phantom 3 Professional, and DJIInspire 1 are small quad-rotor Unmanned Aircraft Systems (UAS). The DJI Phantom 2 Vision+ and Phantom 3 less than 3 pounds. The OJI Inspire 1 weighs less than 7 pounds. The DJI Phantoms and OJIInspire UAS that Soaring View, LLC. will be responsible for also utilizes a mobile ground station. The UAS features a safety return to homefunction that in the event ofa signal loss, the UAS will return to a preset position and land. The return to homefeature can be triggered manually. The remote connects toyour phone or tablet, and a 720 HD view ofeverything as you fly is displayed live. This immersive view streams to you in absolute clarity, enabling safe flying. From takeoffto landing, the Phantom 2, Phantom 3 and Inspire 1 responds to commands while automatically handlingthe most complex aspects of safe, stable flight. Petition Request: Soaring View, LLC requests an exemption by petitionfrom Title 14 ofthe Code of Federal Regulations (14 CFR) Sections; 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1),91.409
.(a)(1} and (2), and 91.417(a) and (b), tothe extent necessaryto allow Soaring View, LLC to safely operate a UAS to perform aerial data collection subjecttothe conditions and limitations required by the FAA as in exemptions Granted in Nos. 11062, 11109, 11112, and 11213, and grant of exemption would be in the public interest
.

The Extent of Reliefthat Soaring View, LLC seeks: 1. Extent of Reliefthat Soaring View, LLC seeks regarding Sections 61.56 Private Pilot Privileges and Limitations: Relieffrom Section 61.113(a) and (b) is requested to allow a Pilot in Command (PIC} holding a current Private Pilots Certificate to operate the Soaring View, LLC DJI Phantom 2 Vision+, Phantom 3 or Inspire 1. The flightwould be complimented by a Visual Observer (VO) who, along with the pilot, will maintain Visual Line ofSight (VLOS) with the mentioned DJI quad-rotor UAS at all times. All operations conducted will be incidental to Soaring View, LLC business. The OJI Phantom 2 Vision+, Phantom 3, and Inspire 1 are not capable ofcarrying passengers. 2. Extent of Reliefthat Soaring View, LLC seeks in regardsto Section 91.7(a) Civil Aircraft Airworthiness: Relieffrom Section 91.7(a) is requested to allowSoaring View, LLC to determine airworthiness ofthe DJI Phantom Vision 2+, Phantom 3 and Inspire 1.As part of this determination the following will be adhered to: a. Priorto the mentioned DJI quad-rotor UAS flight, the PIC will inspect the UAS to ensure it is in a condition that will be conducive for a safe flight. The ground control station will be included inthe above inspections.



### 2 ofSb. Soaring View, LLC will followthe DJI Phantom 2 Vision+, Phantom 3, and Inspire l's aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements.
c. Soaring View, LLC will complywith all DJI manufacturer Safety Bulletins. 3. Extent of Reliefthat Soaring View, LLC seeks in regards to Section 91.119 Minimum Safe Altitudes General relieffrom 91.119 is requested to allow Soaring View, LLC to operate the DJI Phantom 2 Vision+, Phantom 3, and Inspire 1 at altitudes notto exceed 400' 

### AGL over private property at a distance at or greaterthan 5NMfrom the nearest airport as depicted on current Aeronautical Charts. Soaring View, LLC also wishes to be granted exemption to operate at an altitude notgreaterthan 75' AGL (belowtree level) between lNM and 5NM from the nearest airport as depicted on current Aeronautical Charts. Soaring View, LLC will adhere tothe following in orderto maintain an acceptable level ofsafety associated with operations over private property:
a. Soaring View, LLC will display signs inthe immediatevicinity ofoperations stating: "Aerial Photography In Progress. Use Caution." b. Soaring View, LLC will not allowthe DJI Phantom 2 Vision+, Phantom 3 and Inspire 1to operate at a speed greaterthan 10kts.
c. Soaring View, LLC will require the UAS operator (PIC) to be fully trained on the DJI Phantom 2 Vision+, Phantom 3 and Inspire 1 by adheringtothe recommendations contained within the operating manuals. d. Soaring View, LLC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of25 hours oftotaltime as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilotwith multi-rotor UAS. In addition the operatorwill have logged a minimum of5 hours as a UAS pilot operatingthe make and model UAS that Soaring View, LLC operates.
e. Soaring View, LLC will be familiar with and able to manually instruct DJI Phantom 2 Vision+, Phantom 3, and Inspire 1 to Return to Home (RTH) feature
. This feature aborts a operation and automatically returns the UAS to a predetermined GPS safe point. f. Soaring View, LLC will notoperate over private propertywithoutfirst finding a suitable alternate landing spot on the property. g. Soaring View, LLC will abortthe flight in the event ofunpredicted obstacles or emergencies in accordance with the operating documents.
3 ofSh. Soaring View, LLC will utilize atwo man flightteam consisting ofthe Pilot in Control (PIC) and aVisual Observer (VO). Ths team will maintain a Visual Line ofSight with the Phantom 2Vision+, Phantom 3 or Inspire 1 inoperation at all times and remain within hearing ofone another. 

### i. Soaring View, LLC will not permitflight around vessels, vehicles and structures without permission from the owner. 4. Extent of Reliefthat Soaring View, LLC seeks in regards to Section 91.121 Altimeter Settings: Relieffrom 91.121 is requested because the DJI Phantom 2 Vision+, Phantom 

### 3, and Inspire 1 each utilize electronic GPS with a barometric sensor. In orderto maintain an equal level ofsafety that 91.121 requires, the PIC ofthe Soaring View, LLC UAS will abortthe flight in the events thatthe UA loses communications withthe GPS signal. 5. Extent of Reliefthat Soaring View, LLC seeks in regards to Section 91.151(b) Fuel Requirements for Flight inVFR Conditions: Relieffrom 91.151(b) is requested tothe extentthat allows Soaring View, LLC to operatethe DJI Phantom 2Vision+, Phantom 

### 3 or Inspire 1 up to a point (considering wind and forecast weather conditions) thatthere is enough powertofly at normal cruising speed tothe intended landing point and land the UA with 25% battery power remaining. 

### 6. Extent of Reliefthat Soaring View, LLC seeks in regards to Sections 91.405(a), 91.407(a)(l), 91,409(a)(l) and (2), 91.417(a) and (b) which are all associated with Airworthiness Certificate: Relieffrom 91.405(a), 91.407(a)(l) and (2), 91.417(a) and (b) is requested tothe extent that allows Soaring View, LLC to operate the DJI Phantom 2Vision+, Phantom 

### 3, and Inspire 1 Quad-Copter's as necessary. These sections are all related to Airworthiness Certification for small UAS's. Soaring View, LLC would comply in full to anyconditions and limitationsthatthe Administrator would place in orderto receive an approved Grant of Exemption. Public Interest: Aerial videography and photography for real estate listings, construction, architecture, agriculture monitoring, inspections, insurance, marketing, surveying/mapping, sporting events, special events, festivals, weddings, wildlife/nature preservation and conservation, search and rescue has only been availablethrough manned fixed wing aircraft and helicopters, but for small business owners, it's expense has been cost-prohibitive. Grantingthis exemptionto Soaring View, LLC will pose no threattothe public given this small size of quad-copterweighing under7 pounds (which cannot carry passengers), and lack ofcombustible fuel when compared to manned aircraft. The operation ofSoaring View, LLC's quad-copters will minimize ecological damage and promote economic growth by providing information and data to the local businesses and companies who are lookingto relocate or build in the State of Ohio. Two ofthe partner's (Marla 

### K. Bolen and Ashley D. Bolen), ofSoaring View, LLC are active Ohio Licensed Real Estate Brokers who desireto providethis newtechnologytotheir State, in a safe mannerwithin the 4of5guidelines ofthe FAA rules and regulations
. Marla K. Bolen, Ashley D. Bolen, Michael W. Schoonover and Brian Suever, have completed ground school and radio communication courses through the Lima Allen County Airport by

### a licensed pilot instructor on July 23, 2015. Course certificates are available upon request. Soaring View, LLC will use a Licensed Private Pilotto be the PIC ofthe DJI quad-copters, as well as a second person who is the VO, and will complywith the FAA exemption grant and any final rules that may apply for commercial operation. Conclusion: As set forth herein, Soaring View, LLC seeks an exemption pursuant to 14 C.F.R. Section 11
.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DJI Phantom 2 Vision+, Phantom 

### 3, and Inspire 1 UAS commercially within the Real Estate and other mentioned markets. The Administratorwill be assisting small business by granting this petition. In accordance with the FAA Modernization and Reform Act of 2012, Soaring View, LLC respectfully requests that the FAA Administrator grants this petition for exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.23(a) and (c), 61.101{e)(4) and {5), 61
.113{a), 61.315{a}, 91
.7(a), 91
. 119(c), 91.121, 91
.151(a), 91.405{a}, 91.407(a)(1),91.409
.(a)(1) and (2), and 91.417(a) and (b).
Respectfully, Soaring View, LLC

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