Lacey Szekely

Vertical Vantage, Inc. 5600 Caleb Dr. Fallon, NV 89406 (541)727

- 1286 Docket No. FAA

- 2015

- 1256

*Note: After submitting my original petition on April 2, 2015 for exemption with respect to the DJI Phantom 2, DJI released a more sophistica ted UAS; the Inspire 1. I have purchased the DJI Inspire 1 and am seeking an exemption for that UAS. All specifications, manuals and pertinent information are attached. All requests for exemption using the Phantom 2 have been removed from this docket.

Additional Information: 

## I. Regulations from which Exemption is Requested Relief is requested from the following FAR’s:
A. **14 CFR Part 21, Subpart H: A irw**  **orthiness Certificates and 14 CFR 91.203(a) (1)**  **B. 14 CFR 61.56: Flight Review C.14 CFR 6**  **1.113 (a) & (b): Private pilot privileges and limitations D. 14 CF R 91.119: Minimum safe altitudes**  **E. 14 CFR 91.121: A ltimeter settings**  **F. 14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions G. 14 CFR 91.405 (a):Maintenance required; 91**  **.407 (a) (1): Operation after maintenance, preventive**  **maintenance, rebuilding, or alteration; 91.409 (a) (2): Inspections; 91.417 (a) & (b): Maintenance records** 

**A. 14 CFR Part 21; Subpart H: A**  **irw orthiness Certificates and 14 CFR 91.203(a)(1)**  Vertic al Vantage requests exemption from attaining airworthiness certificates required by 14 CFR 91.203(a)(1). Section 333 of the Reform Act allows the FAA to exemptaircraft from the requirement of an airworthiness certificate in consideration of the size,

wei ght, speed, operational capability, and proximity to airports and populated areas of the UAS. Equivalent of Safety The DJI Inspire 1 weighs 6.4 lbs to include payload, no persons on board, and no flammable fuels. The operational location can be preloade d using GPS way points to include route altitude and speed. The DJI Inspire 1 also has a return to home button which safely brings the drone back to its starting point. The PIC and VO will do a thorough preflight to determine the airworthiness of the Ins pire 1 prior to each flight on location. The safety guidelines will be followed from the Inspire 1 User Manual, Flight Operations Manual, and preflight checklist.

**B. 14 CFR 61.56: Flight Review**  Vertical Vantage requests exemption from 14 CFR 61.56 which re quires the PIC to conduct a flight review consisting of a minimum of 1 hour of flight training and 1 hour of ground training. This requirement is not pertinent to the safe operations of the Inspire 1. Equivalent of Safety The equivalent level of safety will be achieved by following the procedures of the manufacturer in the Inspire 1 User Manual and Flight Operations manual. Maintaining currency and proficiency are a top priority for Vertical Vantage Inc. Bi

- monthly flights will be the minimum requireme nt for operation of the Inspire 1. These flights, if not for business purposes will consist of at least 18 minutes (battery life limit) of flight time with Inspire 1, and 10 manual (no GPS) take off and landings.

**C. 14 CFR 61.113: Private pilot privileg**  **es and limitations: Pilot in Command** Vertical Vantage requests exemption from 14 CFR 61.113(a) which states that Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraf t 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. The UAS will only carry a camera onboard for hire. No l iving thing at anytime will be carried, therefor an exemption from the above requirement is requested.Equivalent of Safety

Wh ile being used for commercial and private use, the UAS will never carry live people, animals, or creatures, and therefore has a much lower operational safety requirement than a passenger craft.
**D. 14 CFR 91.119(c): Minimum safe altitudes**  Vertical Vantage request exemption from 14 CFR 91.119(c), which states that except when necessary for takeoff or landing, no person may operate a n aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or sett lement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over ope n 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. Equivalent of Safety Due to the small size, weight, limited speed and absence of flammable liquids o n board, the Inspire 1 is safer than an airplane. Flying will only occur with the proper consent of the property owners and/or local officials. This permission will give ample time for all owners and neighbors to be aware of the times of operation. Mul tiple signs will be posted to ensure people are aware when drone operations are being conducted. At no time will the UAS be operated at or near any airport, exceed 400ft AGL, and or be flown over any person, vessel, vehicle or structure without prior co ordination and permission of the concerned parties (i.e. base operations, FBO, marina operations manager, etc.).
**E. 14 CFR 91.121: altimeter setting** Vertical Vantage requests exemption from 14 CFR 91.121 which states that: (a) Each person operating an a ircraft 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 ro ute 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 aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.The UAS needs an exemption because there is not a configurable barometric altimeter

on board. Equivalent of Safety Precise al titude control is accomplished easily by two methods. The first is done by pre

loading the precise GPS waypoints for the intended route of flight, to include altitude and airspeed. The second is done while operating in a manual flight mode by inputing a maximum allowable altitude into the flight control system on the controller. This limit prevents the Inspire 1 from ever exceeding that altitude. At no time will this limit exceed 400ft AGL in either pre

- planned or manual mode. The Inspire 1 will also remain within visual line of sight at all times.
**F. 14 CFR 91.151(a): Fuel requirements for flight in VFR conditions** Vertical Vantage requests exemption from 14 CFR 91.151(a), which states that: (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. The Inspire 1 uses an 18 minute battery therefore cannot meet the criteria for this requirement. Equivalent of Safety Planning all flights to land after 15 minutes or 25% battery power remaining, whichever comes first , would provide equal safety conditions. The Inspire 1 has a safety feature which automatically returns it directly to the point of origin or planned destination, whichever is closer, upon reaching 25% battery power remaining. This prevents power loss in flight. Additionally if the remote controller is low on batteries the pilot can manually command the Inspire 1 to return to the point of origin with the push of a button. This prevents any case where airborne control of the drone may be lost due to a de ad remote control. This function can be activated at distances greater than visual range, however Vertical Vantage will only operate the UAS in visual line of sight and day VFR conditions. **G. 14 CFR 91.405(a) Maintenance required;91.407(a)(1) Operation a fter**  **maintenance, preventative maintenance, rebuilding, or alteration; 91.409(a) Inspections; 91.417(a)&(b) Maintenance records** 
Vertical Vantage request exemption from maintenance and inspection requirements from 14 CFR 91.405(a), 91.407(a)(1), 91.409(a ), and 91.417(a)&(b). An exemption isrequired for aircraft holding an airworthiness certificate. Presuming an approval for

waiver of 14 CFR Part 21, subpart H and 14 CFR 91.203(a)(1) the Inspire 1 will not require an airworthiness certificate. The Inspire 1 does not hold this certificate. Equivalent of Safety Ensuring the UAS is operational before a flight is key to maintaing an excellent safety record. Keeping a log book for all maintenance preformed and any maintenance test flights will be recorded. This will ensure proper user maintenance is conducted on time. All maintenance will be in accordance with the DJI user manual.



## II. Public Interest

This exemption is in the public’s interest because it offers a more cost effective, more efficient way of supporting their needs with increased safety. The use of a lightweight UAS offers the general public something only successful companies could afford; views from the sky. These aerial views can benefit small and large businesses alike. The Inspire 1 is a safer alternative than other methods like hiring a helicopter or airplane. A UAS can go to places those aircraft cannot and also eliminates the human risk factor. For example, someone wanting to make a short real

- estate clip of their property no longer needs to hire a helicopter which is not very cost effective or as safe. Also, for the purpose of inspecting infrastructure, trenches, agriculture, property lines etc. The UAS provides an annoyance free solution while decreasing the volume of aircraft in the National Airspace above 400 ft AGL. Additionally, the newest DJI UAS, the Inspire 1 incorporates increased safety measures such as push

- button return home capability, low battery sensing which activates automatic return, more efficient low

impa ct blades, and increased telemetry allowing greater control by the pilot. Small drones can have the job done in a more timely manor with less manpower. This much safer alternative will not only mitigate unnecessary risk but provide the public an affordabl e and dependable service. Because of this it is in my opinion that Vertical Vantage working with the Inspire1 would be in the greatest interest of the public.



## III. **Priv acy** All flights will have signed permission/consent forms from the property owner. A mple

time will be given to notify neighbors and signs will be placed in plain sight when the Inspire 1 is aerial. These flights will only occur in predetermined and controlled locations which will protect peoples privacy. Prior permission from the city, county, state or federal officials will be requested if flights need to occur over public lands/property.



## IV. **14 CFR Summary**

I, Lacey Szekely, Vertical Vantage Inc., request exemption from the following rules to commercially operate the Inspire 1 in Natio nal Airspace for Aerial photography, videography, inspection/survey and real estate services. **14 CFR Part 21, Subpart H: A irw**  **orthiness Certificates and 14 CFR 91.203(a) (1)**  **14 CFR 61.56: Flight Review 14 CFR 61.113 (a) & (b): Private pilot priv**  **ileges and limitations 14 CF R 91.119: Minimum safe altitudes**  **14 CFR 91.121: A ltimeter settings**  **14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions 14 CFR 91.405 (a):Maintenance required; 91.407 (a) (1): Operation after**  **maintenance, preventive**  **maintenance, rebuilding, or alteration; 91.409 (a) (2): Inspections; 91.417 (a) & (b): Maintenance records** 

Re

- submitted July 12, 2015 by: Vertical Vantage Inc. Lacey Szekely, Owner 5600 Caleb Dr. Fallon, NV 89406 Telephone: (541) 727

- 1 286 verticalvantageinc@gmail.com