Monday, August 10, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey 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) 

Michael W. 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 using the DJI Phantom 2 Vision+, OJI Phantom 3 Professional, DJI 

Inspire 1. 

UAV DJI Phantom 2 Vision+, Phantom 3 Professional, and DJIInspire 1 

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The 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 OJ I 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 home function that in the event of a signal loss, the UAS will return to a preset position 

and land. 

The return to home feature can be triggered manually. The remote connects to your phone or 

tablet, and a 720 HD view of everything as you fly is displayed live. This immersive view streams to 

you in absolute clarity, enabling safe flying. From takeoff to landing, the Phantom 2, Phantom 3 

and Inspire 1 responds to commands while automatically handling the most complex aspects of 

safe, stable flight. 

Petition Request: Soaring View, LLC requests an exemption by petition from Title 14 of the 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), to the extent necessary to allow Soaring View, LLC to safely operate a UAS to perform 

aerial data collection subject to the 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 Relief that Soaring View, LLC seeks: 

1. Extent of Relief that 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 flight would be 

complimented by a Visual Observer (VO) who, along with the pilot, will maintain Visual Line 

of Sight (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 of carrying passengers. 

2. Extent of Relief that Soaring View, LLC seeks in regards to Section 91. 7(a) Civil Aircraft 

Airworthiness: Relief from Section 91. 7(a) is requested to allow Soaring View, LLC to 

determine airworthiness of the DJI Phantom Vision 2+, Phantom 3 and Inspire 1. As part of 

this determination the following will be adhered to: 

a. Prior to 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 in the above inspections. 

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b. Soaring View, LLC will follow the 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 comply with all DJI manufacturer Safety Bulletins. 

3. Extent of Relief that Soaring View, LLC seeks in regards to Section 91.119 Minimum Safe 

Altitudes General relief from 91.119 is requested to allow Soaring View, LLC to operate the DJI 

Phantom 2 Vision+, Phantom 3, and Inspire 1 at altitudes not to exceed 400' AGL over private 

property at a distance at or greater than 5NM from the nearest airport as depicted on current 

Aeronautical Charts. Soaring View, LLC also wishes to be granted exemption to operate at an 

altitude not greater than 75' AGL (below tree level) between lNM and 5NM from the nearest 

airport as depicted on current Aeronautical Charts. 

Soaring View, LLC will adhere to the following in order to maintain an acceptable level of safety 

associated with operations over private property: 

a. Soaring View, LLC will display signs in the immediate vicinity of operations stating: 

"Aerial Photography In Progress. Use Caution." 

b. Soaring View, LLC will not allow the DJI Phantom 2 Vision+, Phantom 3 and Inspire 

1 to operate at a speed greater than 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 adhering to the 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 of 25 hours of total time as a UAS rotorcraft pilot 

including at least 10 hours logged as a UAS pilot with multi-rotor UAS. In addition 

the operator will have logged a minimum of 5 hours as a UAS pilot operating the 

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 not operate over private property without first finding a 

suitable alternate landing spot on the property. 

g. Soaring View, LLC will abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

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h. Soaring View, LLC will utilize a two man flight team consisting of the Pilot in Control 

(PIC) and a Visual Observer (VO). Ths team will maintain a Visual Line of Sight with 

the Phantom 2 Vision+, Phantom 3 or Inspire 1 in operation at all times and remain 

within hearing of one another. 

i. Soaring View, LLC will not permit flight 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: Relief from 91.121 is requested because the DJI Phantom 2 Vision+, Phantom 3, and 

Inspire 1 each utilize electronic GPS with a barometric sensor. In order to maintain an equal level 

of safety that 91.121 requires, the PIC of the Soaring View, LLC UAS will abort the flight in the 

events that the UA loses communications with the GPS signal. 

5. Extent of Reliefthat Soaring View, LLC seeks in regards to Section 91.151(b) Fuel 

Requirements for Flight in VFR Conditions: Relief from 91.151(b) is requested to the extent that 

allows Soaring View, LLC to operate the DJI Phantom 2 Vision+, Phantom 3 or Inspire 1 up to a 

point (considering wind and forecast weather conditions) that there is enough power to fly at 

normal cruising speed to the intended landing point and land the UA with 25% battery power 

remaining. 

6. Extent of Relief that 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: Relief from 91.405(a), 91.407(a)(l) and (2), 91.417(a) and (b) is requested to the extent 

that allows Soaring View, LLC to operate the DJI Phantom 2 Vision+, 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 any conditions and limitations that the 

Administrator would place in order to 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 available through manned fixed wing aircraft and helicopters, but 

for small business owners, it's expense has been cost-prohibitive. Granting this exemption to 

Soaring View, LLC will pose no threat to the public given this small size of quad-copter weighing 

under 7 pounds (which cannot carry passengers), and lack of combustible fuel when compared to 

manned aircraft. The operation of Soaring 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 looking to relocate or build in the State of Ohio. Two of the partner's 

(Marla K. Bolen and Ashley D. Bolen), of Soaring View, LLC are active Ohio Licensed Real Estate 

Brokers who desire to provide this new technology to their State, in a safe manner within the 

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guidelines of the 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 Pilot to be the 

PIC of the DJI quad-copters, as well as a second person who is the VO, and will comply with 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 of the FAA Modernization and Reform Act of 2012 (FMRA), which 

will permit safe operation of the DJI Phantom 2 Vision+, Phantom 3, and Inspire 1 UAS 

commercially within the Real Estate and other mentioned markets. The Administrator will 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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Marla K. Bolen (member) 

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Ashley D. Bolen {member) 

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Michael W. Schoonover (member) 

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