February 6 , 201 6

Unique Perspective s Aerial Photography

, LLC 10413 SW Tranquil Way

Wil sonville, OR 97070 ( 503 ) 360

- 8437 uniqueperspectivesllc@outlook.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590

Subject: Exemption Request to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14
C.F.R. Part 11, Unique Perspectives Aerial Photography, LLC

, is seeking exemption pursuant to Section 333 of the FAA Modernization and Refo rm Act of 2012 (The Reform Act) , and 14 CFR Part 11. Unique Perspectives Aerial Photography, LLC is requesting to be allowed commercial operation o f designated Unmanned Aircraft Systems ( UAS), provided operations are conducted within the conditions outlined

under current Section 333 of the FAA Modernization and Reform Act of 2012 and any subsequent revisions therein.

Equipment

 DJI Phantom 3 Professional

 DJI Inspire 1

 DJI Spreading Wings S900

Types of Operations The requested exemption would permit the operation of small, unmanned multirotor

aircraft under controlled safe conditions

, to provide the following professional services,

but are not limited to:

 Aerial Survey

 Aerial Photo/video

 Promotional advertising material

 Inspections of real estate properties

 Public entity support operations

 Communications and public infrastructure inspection/monitoring

 Pipeline inspection and patrolling

 Construction site inspection and monitoring

 Real Estate: Residential & Commercial Special Events

 Engineering inspections

Operations w ill be safely conducted within federal guidelines, by a FAA Licensed Pilot with the assistance of an Observer. Operation s would be conducted after carefully reviewing, inspecting, and examining the area of aerial operation to ensure the safety of persons and property.

Requested Exemption Relief Exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

 14 CFR 21

 14 CFR 45.23 (b)

 14 CFR 61.113 (a) & (b)

 14 CFR 91.7 (a)

 14 CFR 91.9 (b) (2)

 14 CFR 91.103 (b)(1), (b)(2)

 14 CFR 91.109

 14 CFR 91.119

 14 CFR 91.121

 14 CFR 91.151 (a)

 14 CFR 91.203 (a) & (b)

 14 CFR 91.405 (a)

 1 4 CFR 407 (a)(1)

 14 CFR 409 (a)(2)

 14 CFR 417 (a) & (b)

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 91.7 (a)

14 CFR 91.203 Given the size, weight, speed, and limited operating area associated with the UAS aircraft to be utilized, exemption from 14 CFR Part 21 Subpart H (Airworthiness Certificates) and 91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under14 CFR Part 11 and Section 333 of the Reform Act.

The Federal Aviation Act U.S.C. 44701 (f) and 333 of the Reform Act both authorize the FAA to Exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports

and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrated that the UAS operated without an airworthiness certificate, in the restricted environment and under conditions propos ed, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. Unique Perspectives Aerial

P hotography, LLC request s an exemption from 14 CFR 91.7 (a ) Civil Aircraft

Airworthiness.14 C.F.R. 45.23(b): Marking of the Aircraft

Unique Perspectives A erial Photography, LLC request s an exemption from 45.23 Marking of the aircraft because the UAS does not have areas large enough on which to

mark certain words or phrases. Additionally two

- inch lettering is difficult to place on

such a small aircraft with dimensions smaller than the minimal lettering requirement.

Even though the UAS will have no airworthiness certificate, an exemption may be needed. The word “Experimental” could be placed on the UAS to comply with 45.29 (f)

in a size suitable for the available space. The UAS is equipped with LED lights to aid in visibility.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

Under 61.113 (a ) and (b) private pilots are limited to non

- commercial operations,

however Unique Perspectives Aerial Photography, LLC can achieve an equivalent level of safety as achieved by current regulations because the UAS does not carry any pilots or

passengers. Until new legislation is passed, a ll Pilots In Command (PIC) will have a Sport or Private Pilot ’ s License , and maintain a FAA current medical certificate.

14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

An exemption to the part will be needed since there is nowhere to place a copy of a flight

manual on board the UAS.

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the U AS is in good condition prior to flight. Inspections wil l be in accordance with the operation

manual for each specific UAS. The preflight inspection will account for all potential discrepancies, i. e., inoperable components, damaged items , or faulty equipment . If the inspection reveals a condition that affects the safe operation of the U AS, 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.

14C.F.R. 91.109: Flight Instruction Section 91.103 provides that no pe rsons may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. By design, UAS are remotely piloted air craft and do not have fully functional dual

contr ols. Flight control is accomplished through the use of a control box that

c ommunicates with the aircraft via radio communications. The FAA has previously approved exemptions for aircraft without fully functional dual controls. The equivalent

level of saf

ety is provided by the fact that neither a pilot nor passengers will be carried inthe aircraft, the ability to control the UAS via radio signals from the controller, and by the

size and speed of the aircraft.

14 CFR 91.119: Minimum Safe Altitudes

Due to the limitation that operations be conducted at or below 400 feet Above Ground Level ( AGL ) , an exemption will be necessary to meet 91.119. The typical UAS flight will be operated and limited as follows:

 Due to battery life, flights of the UAS are lim ited to 10

- 15 minutes

 All flights will remain under 400 feet AGL. The software provided from DJI has

limits which will be set at 398 feet.

 Auto return and l and ing will be set according to the manufacturer’s recommended minimum level of battery power.

 All flights of the UAS will be within visual line of sight (VLOS).

 A ll necessary permissions will be obtained prior to operation.

 Procedures are built into the aircraft to abort flights in the event of safety breaches or potential danger.

14 CFR 91.121: Alti meter Setting

The UAS is not equipped with an altimeter setting device. GPS will be used on board the UAS to determine altitude by reference to the ground (AGL).

14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

An exemption from 91.151 will be necessary as the normal flight time will only be 10

- 15 minutes. The UAS is fueled by battery power and a long duration flight is not possible. Also since all flights will be conducted in Visual Line of Sight ( V LOS), this requirement

is not applica ble.

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration

The UAS fully loaded weighs no more than 55 pounds and is operated without an onboard pilot. Therefore

, there is no ability or place to carry certification and registrat ion documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground flight control station where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.

14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require the owner/operator to have the aircraft inspected as prescribed in subpart E of this part. An equivalent level of safety will be maintained because of the small size and limitations of this UAS. Maintenance will be accomplished by the operator pursuant to the owner ’ s manual. The operator will ensure that the UAS is

in proper working order prior to each flight, perform necessary main tenance, and keep a log of maintenance. The operator is the person most familiar with the UASs operationand is best suited to maintain in an airworthy condition to provide equivalent level of

safety.

Summary

In summary, Unique Perspectives Aerial Photography, LLC respectfully request s exemption f

rom regulations specified above under Section 333 to enable us to operate efficient, low

- risk commercial UAS operations

, for the activities stated abo ve. Unique Perspectives Aerial Photography, LLC along with each PIC will respect at all tim es the space and privacy of citizens and property, while keeping the general public safe.

Granting this request would be in the public interest by allowing our company to provide low cost aerial photography, video, and data collection to businesses and i ndividuals (public) who would otherwise be unable to afford such service. Other benefit s to the public from this service are ; a r educ tion in aircraft noise , r eduction in pollution , and with no fuel on board, the risk of fire due to a crash is all but elim inated. The m ost important benefit to the public is that the use of a UAS over conventional aircraft will reduce the amount of p eople and property exposed to hazards during traditional aerial photography.

The use of a UAS will provide a level of safety at least equal to existing rules and will only be operated in a safe environment that is strictly controlled. Operations will only be conducted after a careful review of the area and weather conditions. Safety for all partie s involved is priority number one.

Sincerely,

Greg Glaze Unique Perspectives Aerial Photography, LLC