July 20, 2015 Jacob Thomas 681 Johnson Rd Oliver Springs, TN 37840 U.S. Department of T ransportation Docket Management System 1200 New Jersey Avenue SE Wa shington, DC 20590 Exemption Request Under Section 333 of the F AA Reform Act and P art 11 of the Fe deral Aviation Regulations Dear Sir or Madam, Pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F .R. P art 11, I, Jacob Thomas seeks an exemption from F eder al Aviation Regulations (“F ARs”) listed below for the DJI Phantom 2/ 3, a quadcopter manufactured by DJI - Innovations. The requested summary exemption would support an application for a “blanket” commercial Certificate of Authorization to use the system to capture aerial photography and videography . T he DJI Phantom 2/ 3 system consists of a lightweight (2.8 lb) battery operated aircraft, a mobile device based ground control station and/or RC Controller , and associated communications equipment. The aircraft carries an onboard gimbaled camera that allows it to obtain photographs and video. The requested exemption would permit, Jacob Thomas, to pursue its commercial interests in providing services to clients using a small adv anced UAS in the following areas: • Real Estate/Architecture • Construction Site Inspection • Marketing • Surveying/Mapping • Sporting Events • Special Events/F estiv als • Radio/ Cellular Communications T owers • Stack InspectionThe regulations from which the exemption is requested are as follows:

- 14 CFR P art 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 61.3

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401 - 91.417)

- FAA P olicy 8900.227 P aragraph 16(c)(4) and P aragraph 16(e)(1) **Unmanned Aircraft System** UAS are o ften seen as superior to helicopters as an aerial video gathering platform due to the smaller size of the devices, more affordable equipment and personnel cost, reduced noise, and a much smaller environmental impact which promotes public safety . I, Jacob Thomas, am petitioning for an exemption to operate a DJI Phantom 2/3 with a built - in stabilized HD camera and the following GPS safety features: • Restricts the height Above Ground Level (AGL) to a specified user generated height. • Restricts the radius o f flight from the ground station to a user - generated distance. • Restricts operations within designated Class B, C, and D airspace including a no - fly zone feature. The DJI Phantom 2/3 also has a failsafe function that is triggered in the event communications are lost between the UAS and the main controller transmitter

. In the unlikely event this occurs, the UAS will return to its point of takeoff and land safety . If communications are restored, the PIC can regain control of flight and land manua lly . These specifications meet with the Model Aircraft Operating Standards (AC 91 - 57) as set below:

· The petitioner will only operate its UAS in line - of- sight of a Pilot in Command (PIC) and/or ground based Visual Observer (VO) and will operate at sites t hat are ‘sufficient distance’ from populated areas within the sterile area described in the FOPM. Such operations willensure that the UAS will “not create a hazard to users of the national

airspace system or the public. ” The orientation of flights will be such that the PIC or VO always has a visual on the rear mounted LED flight Indicator

. Additional safety features on the DJI Phantom 2/3 include an automatic return - to - home feature enacted upon low battery level.

 When flying the UAS within three (3) miles of an airport, airport operators will be notified at least 72 hours prior , and the operator will give the right - of- way to any manned aircraft.

 Pre - flight inspection would include checking battery condition/level in the transmitter

, control tablet, and UA S; a visual/operational check of the propellers; a visual/operational check of the aircraft; a visual/operational check of the motors; a full compass and IMU calibration; a visual/operational check of the transmitting radio control unit; a visual/operation al check of the camera and gimbal unit; and a visual/operational check of the vision positioning system. A check for power - lines, antennas, and other overhead objects would also be performed. Wind and weather conditions would be monitored and be taken into account as a factor for flying.

· The radio frequency of the DJI Phantom 2/3 is in the 2.400 to 2.483 GHz range. Maximum takeoff weight approximately 3000g. Max Ascent/decent speed 5 m/s. Maximum flight Velocity 16 m/s. The UAS to be operated by the petiti oner weighs less than 3 pounds, including all payload (i.e. battery, camera, lens, and stabilized gimbal).

· Te sting, updating and programming the DJI Phantom 2/3 firmware would be done on a monthly schedule.

 Flights will be terminated when battery energy levels reach 25%, allowing sufficient reserve flight time to safely land the UAS. If battery drops below a user specified level the UAS will automatically return to its takeoff point and land safely .
 The UAS will be programmed so it will not be operated a t an altitude that exceeds 400 feet AGL, and not more than 150 feet above a significantly elev ated geographic position from which videography/ photography is planned.

 The aerial perspective would allow my business to provide a unique service to local clie nts that is attractive and competitively priced.

· Given the small size of the UAS and the restricted sterile environmentwithin which it will operate, I, Jacob Thomas , will adhere to the Reform

Act’s safety requirements.

· The DJI Phantom 2/3 will never be flown in the flight path of manned aircraft. With the first condition listed, always keeping a visual line of sight, being of utmost importance to providing a significant level of public safety . In summary, I respectfully request exemption from regulat ions specified above, under Section 333 to enable Jacob Thomas to operate efficient, limited, and low - risk commercial UAS operations for the activities stated above, respecting at all times the space and priv acy of citizens and property, while keeping airs pace safe. Granting this request would be in good public interest by giving an opportunity for real estate photographers and sporting event photographers to offer safer , unique views, and more competitively priced aerial photography to the general public. I am willing and able to modify or amend any part of this request to satisfy the need for an equiv alent level of safety . I look forward to working with your office. Please feel free to contact us at any time if you require additional information or clarif ication. Thank Y

ou for your consideration,

Jacob Thomas 681 Johnson Rd Oliver Springs, TN 37840 thomasinspectionphotography@gmail.com (865)399 - 3551