September 2, 2015

Exemption No. 12724 Regulatory Docket No. FAA

− 20 15

− 2506

Mr. Timothy A. Selman Realistic Image 1111 Classic Drive Valrico, FL 33594

Dear Mr. Selman :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated June 2, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Realistic Image ( hereinafter petitioner or operator ) for an exemption . The petiti oner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography and videography for inspections, sales, advertising, free services to public services, and nature monitoring

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1

. The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in2

consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21

, C ertification pr ocedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is
not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater propo rtions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in a ll material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by th e Administrator, Realistic Image is granted an exemption from 14 CFR §§ 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)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the
ext ent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Realistic Image is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are
not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine

co mpliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective le nses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be de signated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its
op erations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.4

Otherwise, the operator mus t follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any l aw enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon w hich the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other p eople. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Pr ior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the ins pection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UA S manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemptio n, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Pu erto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be5

operated under this exemption, including evasive and emergency maneuvers and maintaining approp riate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficie ncy, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (S VFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made avail able to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses c ommunications or loses its GPS sign al, the UA must return to a
pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manuf acturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct
ope rations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification6
(N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons r emain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/ controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or aut horized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.7

29. The operator must have a m otion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and cer tificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made availa ble to the inspector upon request;
g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes

es sential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise spe cified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on September 30, 2017 , unless sooner super seded or rescinded.

Sincerely,

/ s/ John S. Duncan Director, Flight Standards Service

EnclosuresJune 2, 2015

Timothy A. Selman


### Realistic Image
1111 Classic Dr. Valrico, FL. 33594

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the“Reform Act”) and 14 C.F.R . Part 11, operators at Realistic Image seek an exemption from Federal Aviation Regulations detailed herein for t he operation of lightweight aerial imaging equipment, also referred to throughout as Unmanned Aerial Systems (UAS), as well as their ground based operation equipment described within.



### Realistic Image Aircraft:
Our operation will include a single UAS, manufactur er DJI, referred to hereinafter as the Inspire 1 . The DJI Inspire 1 has the following flight and safety relatable features:

• Inspire 1 is a UAS Quadcopter made by DJI that ha s a fixed gimbal and camera attached to the bottom. Inspire 1 has a maximum weight of 6.47lbs. (2965 grams), and a maxi mum range of 2000m.

• Inspire 1 has built in telemetry to allow the ope rator to see all onboard information relating to th e safety of flight including but not limited to battery percentage rem aining, overall health of the operating system, bui lt-in GPS for position hold and automatic return-to-home, and mul tiple fail-safes for maximum safety.

• The onboard camera allows the operator to record High Definition video, as well as take camera still s. The video is transmitted real-time to the control and operator a llowing the operator to see images to all sides of the UAS utilizing an Apple iPad Air as a monitor for operations.

• DJI Inspire 1 is limited to a maximum assent rate of 5 m/s and has a maximum decent rate of 4 m/s. I t also has a limitation of maximum speed of 22 m/s or 49 mph.

• The Inspire 1 will be operated with a 5700maH lit hium polymer battery allowing for flight times not to exceed 22 minutes. (The Inspire allows for a pre-set to indic ate 30% Battery remaining, which will be set to thi s as a warning reminder to allow for safe landing times).

### Ground Based Guidance and Control System used with the Inspire 1 :

• DJI Inspire 1 is controlled using a DJI transmitt er, operating on a 2.4GHz frequency to a maximum ra nge of 2km. (Specific operating range of 2.400-2.483GHz.) These specifications fall within FCC guidelines for oper ators. Powered by a lithium polymer battery it has a 4 hour time betwee n charges.

• The DJI Inspire 1 transmitter has a built in GPS allowing the Inspire 1 to always know where to retu rn to in the event of
a failure.

• The Inspire 1 transmitter will be controlled by a single operator, but will utilize a Visual Observe r when necessary.



### Flight Control Operator :

• The exclusive operator will be the owner of the I nspire 1. (Timothy A. Selman)

• Over 15 years of remote control experience for co ntrolling small unmanned flight systems.

• Spending over 5 years operating quad rotor units similar to the Inspire 1, and very familiar with Dji (Manufacture of the Inspire) and the operation of the Inspire 1 and all phantom units as well.

Unrelated, however may provide character informatio n and
intent. • Certified NRA Firearms Instructor, for over 4 yea rs. Practicing safety is of utmost concern. • Over 35 years of professional Video & Photography experience working with camera cranes, electronics & aerial video
from conventional and rotor aircraft.

NOTE: 2 nd Control System may be used by another operator for control of the camera ONLY , and will have no influence on the operation of the flight system or flight pat h.

## PRE-FLIGHT CHECK LIST:

This Pre-Flight Check List will be performed prior t o every flight for the safety of people and the uni t itself.

Prior to proceeding to fly always check area and be sure flight path is clear of obstructions and out of flight restricted area.

1) ---Fully charge remote and battery 2) ---close ALL apps in Ipad AND put it in airplane m ode to avoid all interference. 3) ----make sure the DJI pilot app is closed. 4) ----Make sure prop locks are secure 5) ----Turn Remote on FIRST Then Power up Inspire 1. 6) ----Turn ios app on 7) ----Make sure all firmware is up to date and the a pp confirms it 8) ----Check for interference in Lightbridge, adjust channel as required. 9) ----Check Altitude settings and Distance limit. 10) ----Press Camera button and be sure you have a lin k. 11) ----Calibrate Compass 12) ----Be certain that both RX & TX get a good sat lo ck on GPS a min of 6 satellites. 13) ----Be certain that you are not in a restricted fl ight area. 14) ----Press both sticks inwards and down ..mark your home – BE SURE TO CONFIRM HOME POSITION!

Ready to FLY

## Realistic Image will comply with the following at a ll times when conducting commercial operations:

1. All operations will remain outside Class A,B,C,D airspace.

2. Our operating system will be programmed before a ll flights to avoid airports such not to accidental ly fly too close to one. The onboard system will not allow the Inspire 1 to fly into such airspace. This is a n automatic safety feature within the Inspire 1. Howe ver we will also do a map inspection for local airp orts and be sure to mark the area.

3. Operations conducted by Realistic Image will alw ays remain within visual line-of-sight of the UAS. Never to exceed the limitations of operator’s eye sight. We will limit the maximum range of the UAS to not e xceed a single persons visual eye-sight range. Utilizing the software within the UAS will help to maintain t his limit, not to exceed 300m. (.186 miles)

4. Our UAS will never carry an implement not approv ed by the manufacturer and will never exceed a weig ht of 55 lb. as stated within this exemption.

5. All operations conducted by Realistic Image will be at an altitude of less than 400ft AGL, while th e majority of our operations will be at an altitude l ess than 200ft AGL. The Inspire 1 has an automatic altitude limit built in and will be set and checked by our op erator prior to every flight operation as part of t he preflight inspection.

6. Realistic Image will not conduct operations with a speed in excess of 27 knots. The Inspire 1 UAS ha s an automatic speed limiter that will be set and checked prior to every flight by the operator as part of t he preflight inspection checklist.

7. All operations will be conducted in Day VFR cond itions. Minimum flight visibility for all operation will be 5 miles. Minimum cloud ceilings will be 2000ft OVC ( overcast) or BKN (broken).

8. All operations will be conducted away from dense ly populated areas. Realistic Image will work with l ocal officials to make sure any required local documents or permits are attained prior to each flight when required.

9. Prior to each flight our operator will conduct a safety audit of the area to be flown. An assessmen t will be made with regards to persons, property, and weather . This assessment will allow operator to determine whether a safe operation and outcome will be expect ed.

10. Areas of operation and intended use are attache d to this document.

## Our Intended use for the UAS (Inspire 1):

Realistic Image will be utilizing the UAS for multi ple video and photo projects. Including:

• Insurance Inspections of Home and Property

Florida is known for storm damage, we provide photo graphy for this type of disaster already. However, using a UAS to conduct inspections of property and structures coul d save a significant amount of time and add a safet y factor in many cases as to not sending a human in these environmen ts and rubble. Realistic Image can use the UAS for an overview of the situation and provide documentation of the even t that took place.

• Large Structure Roofing Inspections

Large Structure such as warehouse and buildings wit h thin tin roofing require safe methods for inspect ion. UAS provides a much safer alternative to having a person walk on the roofing. The report feedback from video and photos can aid s ignificantly in providing a cost summary for repair or the need for repair. With Florida weather there is a great need for this type of inspection.

• Yacht Sales Photography and Videography

In the State of Florida Realistic Image has found a great need to use UAS to capture video and photos for Yacht sales throughout the state. The use of UAS will offer ou r customers a cost effective alternative to convent ional aircraft. Using the Inspire will provide a safer alternative and a much lower altitude method of capturing images.

• Commercial Advertising Video and Photography

Realistic Image has a significant amount of interes t in taking video and photos for advertising in the central Florida area. Utilizing the UAS will offer a significant improvem ent to our company with regards to both safety and cost. A planned view from a higher perspective captured with a much safer alternative to ladders, helicopter or other methods of capturing this type of image.

• Real Estate Photography and Videography

We currently specialize in Real Estate photography and Florida is one of the fastest growing areas in America. By capturing images using a UAS, we can capture images to provide people with a more cost effective metho d. Currently we use boats for ocean views, by using the Inspire we can cut expense and provide a safer alternative

.

• FREE services offered to our community, firefighter and state officials.

Our services will be offered if the need is require d for after storm search, wild fire feedback to fir efighters and additional services which may require a quick to dispatch low altitude monitoring system. These services will in crease safety
associated with law enforcement and search and resc ue. The services will be offered free of charge to the community.

• Nature Monitoring

Florida is known for it’s amazing array of bird pop ulation, by using a UAS to for aiding in studies wi ll provide valuable feedback on population, breeding stats and other im portant information. The Inspire can fly at a low altitude distance away from them to offer this information without in terference to the bird community. Realistic Image would provide
this as a FREE service to select students of our lo cal colleges. We truly enjoy working with the comm unity when we can.

## The current regulations that we seek exemption from are:

A. 14 CFR Part 21 (h) Airworthiness Certification

• Under this part we seek exemption to apply for an d maintain airworthiness certification for our UAS. Model and serial number of our UAS will be provided within.

B. 14 CFR Part 91 Subpart A: Airworthiness 91.7 (a) Civil Aircraft Airworthiness

• Under this part, “no person may operate a civil a ircraft unless it is in airworthy condition.”

• We seek exemption from this part, as we will keep our UAS in a safe, reliable, and airworthy conditi on, it may not meet all standards as set for by this part of the F AR’s. Operator will assume all responsibility for d etermining that the UAS is in a condition safe for flight, as well as a condition that will not harm other people or prope rty. This will be accomplished using specific guidelines from the man ufacture, DJI, as well as following any guidance se t for routine
maintenance.

C. 14 CFR Part 91 Subpart C: 91.203: Certifications Required

• Under this part, (a) no person may operate an air craft unless it has within it the following; An app ropriate and current airworthiness certificate. This part also includes regulations regarding the use of fuel tanks, which do not apply to the Inspire 1 because it operates on battery power only

.
• We seek exemption from this part as an airworthin ess certificate does not apply to our specific UAS.

D. 14 CFR Part 91 Subpart B; 91.119 Minimum Safe Al titude

• Under this part, (a) no person may operate an air craft below an altitude allowing, if power fails, a n emergency landing
without undue hazard.

(c) over other than congested areas an altitude bel ow 500ft AGL.

• We seek exemption from this part due to the natur e of the operation, as well as the safety procedure s set forth will have little to no risk of damaging any person or st ructure.

E. 14 CFR Part 91 Subpart B; 91.121 (a)(1) Altimete r Setting

• This section pertains to setting an altimeter set ting below 18000ft to a reported altimeter reportin g station setting.

• We seek expedition from this part as our UAS has no way of setting an alternate altimeter setting. W ith a built-in barometer, the Inspire 1 uses real-time data to det ermine altitude each flight. Operating less than 40 0ft AGL, we feel our UAS will have little to no impact on other part icipating aircraft. Also, with flights not to excee d 16 minutes (22 minute battery, and landing at 30% battery remainin g) our UAS will not need to recalibrate its altimet er while in flight.F. 14 CFR Part 91 Subpart B; 91.151 Fuel Required f or VFR flight

• This section contains requirements for fuel in VF R flight for combustion engines.

• We seek exemption from this part as our UAS opera tes off of battery power only. We feel our operatio ns will not compromise safety to either the operator or propert y as we have set forth a procedure to land our UAS when the battery level reaches 30%, or approximately 6 minut es flight time remaining. The Inspire 1 has built i n battery telemetry that feeds information real time to the o perator and an alarm notifies the operator of minim um battery level remaining.

G. 14 CFR Part 91 Subpart E; 91.405 Maintenance Req uired

• This section contains requirements for the operat or to maintain and have inspected the aircraft in a ccordance with Part 43 of the CFR. Under this section it is requir ed to keep maintenance logbooks with the aircraft. It also requires the aircraft to contain placards of the inoperative equ ipment.

• We seek exemption from this part as our UAS will not be operating with inoperative equipment and is too small to carry logbooks. We also seek exemption due to no ce rtified maintenance technicians will work on the UA S. Under this exemption Realistic Image will be completing pre-fl ight and post-flight inspections, and any required maintenance or repairs will be completed by the manufacturer, DJI, or one of its certified technicians.

H. 14 CFR Part 91 Subpart E; 91.407 Operation After Maintenance

• This part requires an aircraft that has undergone repair, rebuilding, alterations, or general mainte nance to be approved by an authorized person required by CFR 43 .9 and CFR 43.11.

• We seek exemption from this part as these inspect ions do not pertain to our operation of the UAS. Th e operator will be responsible for determining the airworthiness of the UAS prior to each flight. After maintenance pr ovided by the manufacturer, the operator will complete test fligh ts before any operation in the vicinity of persons or property to assure all systems are functioning normally.

I. 14 CFR Part 91 Subpart E; 91.409 Inspections

• This section provides details of the required ins pection on an aircraft. No person will operate an a ircraft unless in the preceding 12 months has had (1) an annual inspectio n (2) an issuance of an airworthiness certificate.

• We seek exemption from this part as the inspectio n and airworthiness certificate to not apply to our UAS. Our operator will be responsible for the inspection and airworthiness determination prior to each flight a nd will have the UAS repaired by the manufacturer or one of its cert ified technicians, if the UAS is found to be in a s tate other than
intended but the manufacturer.

J. 14 CFR Part 91 Subpart E; 91.417 Maintenance Rec ords

• This section requires the owner/operator to compl ete and retain a list of all records pertaining to the work performed, the date of completion, the signature of the inspec tor, and all work performed on the aircraft.

• We seek exemption from this part as the inspectio ns and technician work will not apply. Our operator will be responsible for determining the airworthiness of th e UAS prior to each flight and will not operate the UAS in any condition other than intended by the manufacturer. The operator will keep records of all work complete d by the maintenance facility.K. 14 CFR Part 91 Subpart B; 91.103 Preflight Actio n

• This section requires each pilot prior to flight will become familiar will all available information pertaining to that flight including runway lengths, flight information, weath er, etc. For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance informat ion include; all applicable information relating to aircraft performance, airport elevation, runway slope, aircr aft gross weight, wind and temperature.

• We seek exemption from this part as our operator, while utilizing all available information for the safe operation of the UAS, will not have the above information availa ble for most flights. The operator will use good ju dgement and all
resources available to ascertain the information ne cessary for the safe operation of the UAS. A prefli ght inspection will be accomplished according to the manufactures instructions prior to each flight.

L. 14 CFR Part 91 Subpart B; 91.105 Flight Crew mem bers Stations

• This section pertains to the required crew member s being at their stations during all phases of flig ht, and requires the
use of seat belts and shoulder harnesses.

• We seek exemption from this section as it pertain s to aircraft with flight crew member stations. Our UAS does not
have such stations.

M. 14 CFR Part 91 Subpart B; 91.9 Placement of Manu al

• This part states no aircraft may operate without a manual onboard the aircraft.

• Our UAS is not large enough to carry such operati ng manual. We will however carry a current manufact urer manual in the UAS carrying case along with the operator on all flights.

N. 14 CFR Part 45.23

• Under this part, it is required that each operato r must display on that aircraft marks consisting of the Roman capital N followed by the registration number of the aircraft

.

• Our UAS is too small to attach the “N” number. We seek exemption from this part as we will be attach ing the registration or serial number as required on the UA S.Thank you for considering these exemptions.

If there is any additional information required ple ase contact us.

Sincerely,

Timothy A. Selman Realistic Image

tim@realisticimage.com