### June 10, 2015

Hon. Michael Huerta

Administrator

Federal Aviation Administration U. S. Department of Transportation Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from certain parts of the FARs.

Dear Administrator Huerta:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Len Davis, the owner of Pure Imagination, Inc, a Creative Agency, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow him to operate a small Unmanned Aircraft System (“sUAS”) under th e conditions and

limitations set forth in this Petition.

The requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is (1) limited, (2) predetermined, and (3) would p rovide safety enhancements to the already safe aerial video production operations presently using manned helicopters and airplanes. Approval of this exemption would thereby enhance safety and fulfill the FAA Administrator’s responsibilities to “

... establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. The name and address of the applicant is:

Len Davis Company: Pure Imagination, Inc Address: 12 E Wilson St., Batavia, IL 6 0510 Telephone: (630) 406

- 7990 x202 Mobile: (630) 301

- 0090

Email: ldavis@purei.com

Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. § 45.23(b) 14 CFR § 61.3 14 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2) 14 C.F.R. § 91.103 14 C.F.R. § 91.109 14 C.F. R. § 91.119 14 C.F.R. § 91.121 14 CFR § 91.151 (a) 14 CFR § 91.203 (a) & (b) 14 CFR § 91.205(b)

### 14 CFR § 91.215 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2)

14 CFR § 417 (a) & (b)

The Appendix describes the FARs from which an exemption is requested and summarizes the justification for each requested exemption.

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the

Reform Act, which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making th is determination, the Administrator must determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Op eration of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a).

If the Administrator determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333(c) (emphasis added).

Th e Secretary has delegated his aviation authority to the Administrator of the FAA.

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of the Federal Aviation Act if Administrator finds the exemption in th e public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1).

The petitioner is a professional videographer, photographer and owner of a creative agency that has been in business for 15 years. His assignments include capturing photos and video for multiple clients utilizing various professional equipment for the production of educational, corporate, sales, promotional, training and instructional videos.

The wide availability of small Unmanned Aircraft Systems , also known as “UAS,” capable of carrying high

- quality video cameras and priced at affordable levels intrigued the petitioner. His entire professional career has involved exploring new technologies and adapting them to capture good imagery to inform the p ublic. In December 2014, he bought a DJI Inspire 1. He has flown it for a total of 40 hours for recreational purposes, exploring the potential and the limitations of its video subsystem.

He is pleased with the quality of the imagery captured and has edited it into a number of photographic vignettes that meet his high standards for technical quality and artistic merit. Now, a number of clients have heard about Petitioner’s activities and h ave seen the results and are pressing Petitioner to undertake additional UAS photography and videography for compensation.

### He understands that this is not now permissible unless he obtains special permission from the FAA. Many competitors of Petitioner a re actively flying sUAS to conduct aerial photography for commercial purposes, notwithstanding the FAA’s stated prohibition. He also notes and has read the congressional mandate in sections 332 and 333 of the FAA Revitalization and Reform

Act of 2012 that the FAA move quickly to accommodate the economic and societal benefits that can result from widespread deployment of sUAS technology. Accordingly, Petitioner applies for authorization under the Federal Aviation Act, and the FARs rules to undertake the

foll owing activities for commercial purposes. Unless the Petition is granted, Petitioner will be at a significant competitive advantage if he, as he prefers, complies with FAA policy.

Vehicle The UAS proposed for use by the petitioner is the Inspire 1 provi ded by DJI.com (DJI), used in conjunction with DJI hardware/software controllers, data signal processing, and GPS stabilization and navigation electronics. It weighs almost 6.5 pounds with the battery. The max speed is 42.7 knots.

When GPS is available, the Home Point (the location the operator is standing) automatically refreshes, so the UAS always knows where the operator is even if he moves around. When the operator commands the UAS to return to Home Point, or in case of an emergency, the UAS

automatic ally returns and lands safely.

The Inspire 1 User Manual and all of the specs can be viewed online here: http://www.dji.com/product/inspire

- 1/spec.

Flight profiles The petitioner will program the UAS so that it will not fly above 400 feet above ground l evel, or more than 1500 feet away from him. He will carefully preflight the vehicle before each mission to assure that its compass and GPS system are properly calibrated and that the return

- to

- home feature, altitude, and radius limitations work.

He will operate it only over largely unpopulated areas where the potential of uncontrolled descent to cause injury or damage is low. He will not operate it in controlled airspace. In the unlikely event that a manned aircraft flies below 400 feet AGL where the petitioners operating his UAS , he will keep both the vehicle and manned aircraft in sight and avoid the manned

aircraft.

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform Act relating to size, weight, sp eed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security. The Petition justifies grant of the requested exemptions allow the Petitioner to obtain aerial photography with his UAS

.

Respectfully submitted,

Len Davis

### Appendix

FAR section Subject Justification

14 CFR § 45.23(b) Requirement to display registration number on vehicle Insufficient space on vehicle

14 CFR Part

21 Aircraft certification requirements and procedures Designed for manned aircraft; not suitable

for off

- the

- shelf sUAS

14 CFR § 61.3 Requirement for pilot certificate Part 61 requirements designed for manned aircraft, not sUAS; petition describes traini ng for sUAS operator

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; not suitable

for off

- the

- shelf sUAS

14 CFR § 91.9 (b) (2) Requirement for manual to be available in the cockpit No one aboard to read manual

14 CFR §

9 1.103(b) Requirement for crew members

to be onboard Unmanned vehicle

14 CFR §

91.109 Requirement for dual controls during flight instruction No one aboard to operate controls

14 CFR §

91.119 Minimum altitudes for safe flight Safety requires operation below these

altitudes

14 CFR §

91.121 Altimeter settings No one aboard to read altimeter

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel

14 CFR § 91.203 (a) & (b) Requirement for registration and

airworthiness certificates to be

onboard No one aboard to read certificates

14 CFR § 91.205(b) Cockpit instruments No one aboard to read