January 15, 2016

US Department of Transportation
Docket Management System

Federal Aviation Administration
1200 New Jersey Avenue, SE
Washington, DC

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation

Regulations from 14 C.F.R. §61.113(a)&(b); 14 C.F.R. §45.23; 14 C.F.R. §91.9; 14

C.F.R. §91.119(c); 14 C.F.R. §91.121; 14 C.F.R. §91.151; 14 C.F.R. §91.405(a); 14

C.F.R. §91.407(a); 14 C.F.R. §91.409(a)(1)&(2); 14 C.F.R. §91.417(a)&(b).

Submitted by:

Scott Robinson
dba Galago Visio n

PO Box 723051
San Diego, CA 92172
scott@galagovision.com

858

- 444

- 7010

Dear Sir or Madam,

I, Scott Robinson , founder of Galago Vision, formally request Section 333 exemptions from several provisions of Title 14 of the Code of Federal Regulations. These exemptions will allow my company to operate the small, unmanned aerial system s (sUAS ’s ) safely for compensation in the following aspects of aerial video and photography:

• The marketing of real

- estate properties.

• Monitoring of residential construction.

• A erial photography and video of private events.

As described herein I, Scott Robinson, am a small business owner within the State of California; experienced in flying hobby type quad

- copters for recreational purposes. I have two hobby grade quad

- copter UAS’s (Phantom 3, and Hexo+) equipped with an attached camera with intent for aerial videography/cinematography to augment real

estate l istings, land development, events, promotional videos; following exemption and approval by the FAA.

The Hexo+ i s a small, unmanned Arial system very similar in size, weight, and function to

the DJI Phantom 3 for referen ce. My goals are to operate these sys tem s as safely as possible no higher than 200 feet AGL under the blanket COA and in compliance with the protocols described herein or as otherwise established by the FAA.Granting my request complies with the Secretary of Transportation’s (FAA

Administrato r’s) responsibilities and authority to not only integrate s UAS's into the

National Air

- Space System, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the National Air

- Space System” under Section 333(c) of the Reform Act specific to the use of s UAS's for real estate, photography and videography purposes. Further I, Scott Robinson dba Galago Vision , will conduct my operations in compliance with the protocols described herein or as oth erwise established by the FAA.

For the reasons stated below I, Scott Robinson dba Galago Vision , respectfully request the grant of an exemption allowing me to operate ultra

- lightweight, remote controlled

s UAS’s to enhance real estate listing videos for hom eowners who cannot afford expensive manned aircraft. This will promote local economic growth . This will keep public safety in mind by keeping heavier manned aircraft containing combustible fuel that poses potential public hazard out of these dangerous area s.



### Sections from Which Seeking Exemption:

The specific sections I require relief from are as follows:

Section 333 Aircraft Exemption Status:

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a consideration of the size, weight, speed, operational capability of the particular UAS, as well as its proximity to airports and populated areas.

14 C.F.R. §61.113(a)&(b) entitled Private pilot privileges and limitations

**.** (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A pr ivate pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and
(2) The aircraft does not carry passengers or property for compensation or hire.

14 C.F.R. §45.23 Display of markings; general. (a) Each operator of an aircraft must display on that aircraft marks consisting of the

Roman capital letter “N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or

pro visionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,”

“ experimental,” or “provisional,” as applicable.14 C.F.R. §91.9 Civil aircraft flight manual, marking, and placard requirements: (a) Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operati ng limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry. (b) No person may operate a U.S.

- registered civil aircraft

— (1) For which a n Airplane or Rotorcraft Flight Manual is required by §21.5 of this chapter unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided for in §121.141(b); and
(2) For which an Airplane or Rotorcraf t Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. (c) No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. (d) Any person taking off or landing a helicopter certificated under part 29 of this chapter at a heliport constructed over water may make such mom entary flight as is necessary

for takeoff or landing through the prohibited range of the limiting height

- speed envelope established for the helicopter if that flight through the prohibited range takes place over water on which a safe ditching can be accomp lished and if the helicopter

is amphibious or is equipped with floats or other emergency flotation gear adequate to accomplish a safe emergency ditching on open water.

14 C.F.R. §91.119(c) Minimum safe altitudes: General (a) Over other than congested areas. A n altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

14 C.F.R. §91.121 Altimeter settings: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)( I ) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircr aft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92′′ Hg

.

14 C.F.R. §91.151 Fuel requirements for flight in VFR conditions: (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of

inten ded landing and, assuming normal cruising speed, to fly after that for at least 20

minutes.

14 C.F.R. §91.405(a) Maintenance required: (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;

14 C.F.R. §91.407 (a) Operation after maintenance, preventive maintenance, rebuilding, or alteration: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and
(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made.

14 C.F.R. §91.409(a)(1)&(2) Inspections: (a) Except as provided in paragraph (c) of this section, no pe rson may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter;

or (2) An ins pection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

14 C.F.R. §91.417(a)&(b) Maintenance records: (a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must

include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of c ompletion of the work performed; and (iii) The signature, and certificate number of the person approving the

aircraft for return to service.
(2) Records containing the following information: (iv) The total time in service of the airframe, each engine, each propeller,

and each rotor. (v) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (vi) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.(vii) The current inspection status of the aircraft, including the time since

the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (viii) The current status of applicable airworthiness directives (AD) and

safet y directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next

action is required. (ix) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until

the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircra ft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.



### Extent of Relief:

Section 333 Aircraft Exemption Status:

DJI Phantom 3 and Hexo+ sUAS ’ s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Galago Vision will ensure that

the DJI Phantom 3 and Hexo+ sUAS ’ s are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and Hexo+ Instruction Manual) prior to every flight

. This is in line with other

similar sUAS ’s that have received exemptions for c ertificate of airworthiness.

14 C.F.R. §61.113(a)&(b) entitled private pilot privileges and limitations. Relief from Section 61.113(a) and (b), is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Sect ion 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carr y passengers or property for compensation

or hire.

As set forth more fully below, Galago Vision submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the sUAS’s unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 or Hexo+ sUAS ’s in a manner consistent with the operations specifications as described in this exemption, including evasive and

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.14 C.F.R. §45.23 Display of marks; general. Even though the sUAS ’s will have no airworthiness certificate, an exemption would be

needed as the sUAS ’s will have no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS ’s , two

- inch lettering is impossible. Galago Vision will place the registration number and experimental markings in the largest lettering practical.

14 C.F.R. §91.9 Civil aircraft flight manual, marking, and placard requirements: The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have imme diate access to it. All manuals, flight logs and exemptions will be with the ground station in a binder and

available for law enforcement.

14 C.F.R. §91.119 Minimum safe altitudes: Galago Vision will never operate at an altitude greater than 200 AGL. The sUAS ’ s will operate in

safe areas away from the public and traffic. Given the size, weight, maneuverability, and speed of

the s UAS ’s , an equivalent or higher level of safety will be achieved. The s UAS’s will never operate at an altitude greater than 200 AGL, safely below the standard of 400 AGL.

14 C.F.R. §91.121 Altimeter Settings: Altimeter settings are inapplicable as the DJI Phantom 3 and Hexo+ utilizes electronic global positioning systems (GPS) w ith a barometric sensor.

14 C.F.R. §91.151 Fuel requirements for flight in VFR conditions: Relief from this section, is requested to the extent required to allow flights of the battery powered sUAS’s during daylight hours in visual meteorological conditions, under visual flight rules (VFR), for a total duration of 15 minutes , and a ssuming normal cruising speed, to fly after that for at least 5 minutes. Galago Vision seeks the requested relief because without an exemption, the flight time duration o f the battery powered sUAS’s will severely constrain the practicality of any aerial video or still photo flight operations proposes to be conducted pursuant to this petition.

14 C.F.R. §91.405(a) Maintenance required, 14 C.F.R. §91.407(a) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. §91.409(a)(1)&(2) Inspections, 14 C.F.R. §91.417(a)&(b) Maintenance Records: Galago Vision requests relief from these regulations as they relate to §43 and apply to the

aircraft with a certificate of airworthiness. Since the DJI Phantom 3 and Hexo+ do not require a Certificate of Airworthiness, relief is requested. As a model aircraft pilot, I take maintenance very seriously. The sUAS’s are always serviced in accordan ce with the guidance in the manufacturer provided manuals. The manufacturer will also be consulted should any maintenance discrepancies arise. Maintenance records are logged and

annotated in the aircraft flight log. All manuals, flight logs, and exemptions will be with the ground station in a binder and available for law enforcement.



### How the Request Benefits the Public:

My company, Galago Vision , can and will benefit the public in the aspects of safety and economic growth. First and foremost, safety is the biggest public benefit of utilizing Galago

Vision . My services reduce the risk of injury and death to the general public, discouraging climbing tall ladders or trees with a camera to gain a similar vantage point. It also alleviates the inherent dangers of operating a full scale aircraft at low altitudes whilecapturing photos and video. Aerial photos and video from a sUAS give customers a very unique and valuable perspective of properties and events. Galago Vision ’s sUAS’s provides one of a kind high

- definition and gyro

- stabilized video and photographs. These

luxuries would normally be reserved for customers that could afford to charter a full scale

aircraft and video crew. My service brings that product to the average citizen.



### Why the Exemption Does Not Adversely Affect Safety:

Safety is of the upmost importance to Galago Vision. The DJI Phantom 3 and Hexo+ fall well below the maximum limitations for a sUAS. It has a fully integrated GPS that returns

the sUAS back to a predetermined point to land automatically if there is a signal loss or if

the Home switch is activated from the ground transmitting station. The switch is easily accessed and can be activated by the Visual Observer in the unlikely event that the Pilot

in Command is incapacitated ; furthermore, it will be part of the preflight brief. Galago

Vision never flies over any persons, vessels or structures that are non

- participating. Sound judgment, airmanship, and experience are used while flying near participants. The

sUAS ’s will only be flown over property that Galago Vision has prior client permission to
operate over. Galago Vision operates using Line of Sight (LOS) operations in daytime

VFR conditions at all times. Galago Vision never plans a flight longer than 15 minutes to

allow a minimum of 25% battery remaining at landing. Galago Vision always consults aviation charts and will honor the blanket COA parameters

. Galago Vision never operates

at an altitude higher than 200

- feet AGL. Galago Vision also utilizes a Visual Observer

thro ughout the flights entirety to include an extensive brief prior to flight. An extensive preflight and post

- flight check will be performed before and after each flight. additionally, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may pre scribe special conditions for the intended operation of the sUAS ’ s, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Secti ons 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)&(b).

Respectfully submitted,

Scott Robinson dba Galago Vision

PO Box 723051 San Diego, CA 92172 scott@galagovision.com

858

- 444

- 7010

### Appendix A

Summary for Federal Register Publication

Petitioner Scott Robinson d/b/a Galago Vision

Sections of 14 C.F.R. that are affected.

Section 333 Aircraft Exemption Status

- Relief from certificate of air worthiness. 14 C.F.R. §61.113(a)&(b)

– Entitled Private pilot privileges and limitations. 14 C.F.R. §45.23

- Relief of markings size. 14 C.F.R. §91.9

- Relief from aircraft flight manual, marking, and placard requirements. 14 C.F.R. §91.119(c)

- Reli ef from minimum safe altitudes. 14 C.F.R. §91.121

– Relief from altimeter settings. 14 C.F.R. §91.151

– Relief from VFR fuel requirements. 14 C.F.R. §91.405(a)

– Relief from m aintenance required. 14 C.F.R. §91.407(a)

– Relief from operation after maintenance. 14 C.F.R. §91.409(a)(1)&(2)

– Relief from inspections. 14 C.F.R. §91.417(a)&(b)

– Relief from maintenance records.

Petitioner seeks relief from the preceding regulations and requirements to operate the

DJI Phantom 3 and Hexo+ sUAS ’s for the purpose of compensated aerial video and photography. The operations will include real

- estate, residential construction, and private

events. It is the belief of Scott Robinson d/b/a Galago Vision that these operations are pursuant to the FAA’s stance of legally entering the sUAS marketplace by operating safely in the National Airspace System.

Galago Vision will honor the blanket 200

- foot AGL blanket COA by adhering to the following flight parameters as well as other limitation the Adminis tration finds necessary to establish an equivalent level of safety

.

No flight with in:

• 5 nautical miles (NM) from an airport having an operational control tower; or

• 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or

• 2 NM from an airport without a published instrument flight procedure or an operational tower; or

• 2 NM from a heliport with a published instrument flight procedure

Scott Robinson dba Galago Vision

PO Box 723051 San Diego, CA 92172 scott@galagovision.com

858

- 444

- 7010