June 25, 2015 

### Eagle Drone Imaging, LLC Contact: David E. Altobelli 11 Ascot Park Nashua, NH 03063 Email Daltobelli1@mac.com Phone (603) 305-7705

U.S. Department OfTransportation Docket Operations West Building Ground Floor, Room w12-140 1200 New JerseyAvenue, SE., Washington, DC 20590

Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11

ofthe FederalAviation Regulations

Dear Sir or Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the reform act) and 14 CFR Part 11, 

### Eagle Drone Imaging, LLC, a companythat owns and operates Small Unmanned Aircraft Systems (UAS), requests to be exempted from the Federal Aviation Regulations (FAR) listed below so that

### Eagle Drone Imaging, LLCmay operate UAS commercially in airspace regulated bythe FAA, as long as such operations are conducted within and under the conditions outlined herein or as maybe established bythe FAA as requiredby Section 333.

Company Background and Planned Operations 

### Eagle Drone Imaging, LLC is a New Hampshire company owned by David E. Altobelli. Mr. Altobelli is a commercially rated helicopter pilot, with a currentmedical certificate and flight review, and nearly 320 hours as PIC. He also has an estimated 25 hours ofexperience flying UAS and is familiar with the operations and the maintenance ofthe hardware and software updates for these systems. Operations will involve collection ofaerial imaging and sensor data to enable inspections and assessments ofindustrial structures, agricultural management and surveys, and photography and videography (e.g. land and waterbased venues for imaging real-estate, naturaljscenic settings, outings, functions and events).

Equivalent Level ofSafety The requested exception would permitthe operation ofa lightweight (less than 55 lbs. total takeoffweight) UAS under controlled conditions for commercial use by a certified commercial helicopter pilot thereby enhancing safety and fulfilling the Secretary ofTransportation's (the FAA Administrator's) responsibility to" establish requirements for safe operation ofsuch aircraft systems in national airspacesystems", Section 333(c) ofthe Reform Act. The enhanced safetyusing a UAS in comparison to a manned aircraft, including helicopters ofsignificantly greater proportion and carrying a crewwith flammable fuel is self-evident and beneficial to the public's interest, while being able to provide commerciallybeneficial information and data more quickly, accurately, safely and economicallywith greatly reduced environmental impact. All operations will be conducted from safe and appropriate distances for the specific operation. All operations will be performed with the public's safety and rightto privacy safeguarded at all times.

UAS Devices Eagle Drone Imaging's UAS(s) are battery-powered, weighingwell less than 55 pounds including payload. Our UAS fleet will include the DJI Phantom Series, the DJI Inspire Series, and the SpreadingWings Series ofRC multi-prop helicopters. The specific UAS(s) to be initially included in ourfleet:

Parameter DJI Phantom 2 DJI Inspire 1 SpreadingWings Vision Plus S1000+ Type 4 Prop RC helicopter 4 Prop RC helicopter 8 Prop RC helicopter Weight 2.71bs. 6.471bs. 24.2 lbs. max Flight Speed (max1 29 knots 42 knots 42 knots Flight Time 20min. 18min. 15 min. Camera Integrated Integrated DSLRcamera
They operate at speeds well less than 87 knots and have the capabilityto hover and

move in the vertical and horizontal planes simultaneouslyin a preciselycontrolled

manner. Our primaryintentis to utilize them atmuch slower speeds for ourimaging and data collection applications. As upgrades become available, wewould like to be able to incorporate the more advanced systems in each series into our operations after we have thoroughly reviewed new documentation and have trained to be capable and comfortable with their flying characteristics.

StatutoryAuthorityfor Exemptions Eagle Drone Imaging, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relieffrom any currently applicable FAR'S operatingto preventEagle Drone Imaging, LLC from future commercial use ofsmall UAS to operate in the national airspace system as described below. The reform Act section 332 provides for such integration ofcivil unmanned aircraft into our national airspace system as it is in the public's interestto do so. Eagle Drone Imaging, LLC's UAS(s) will meetthe definition of"small unmanned aircraft" as defined in Section 331 and therefore the integration ofthese UAS are expressly contemplated bythe Reform Act. Eagle Drone Imaging, LLCwould like to operate its' lightweight UAS(s) priorto the time period bywhich the Reform Act requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary ofTransportation to considerwhether certain unmanned aircraft systems may operate safely in national airspace before completion ofthe rule making required under Section 332 ofthe reform Act. Inmaking this determination, the Secretary ofTransportation is required to determine which UAS do create a hazard to users ofthe national airspace system orthe public

or pose a threatto national securityin light ofthe following:

-The UAS size, speed, weight and operational capability

- Operation ofthe UAS in close proximity to airports and populated areas -Operation ofthe UAS within visual line ofsight ofthe operator
Reform Act 333(a). Ifthe secretary determines that such vehicles "may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.


### Eagle Drone Imaging, LLCutilizes multi-prop RC helicopters weighing less than SSlbs. that operate at speeds less than 50 knots and have the capability
to hover and operate in the vertical and horizontal plane simultaneously in a precisely controlled manner. The UAS will operate onlywithin the visual line-of-sight ofthe operatorwithin a controlled flight area and at 400 feet above ground level (AGL) orless. Most operations are envisioned atless than 100 feetAGL. These will notpresenta hazard to the national airspace nor the public.

The very small nature ofthese UAS combined with the risk management presentedbelow, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allowing commercial operations ofUAS to commence immediately. Also due to the size ofUAS and the controlled areas and the low altitudes in which theywill operate, approval ofthis exemption presents no national security issues and absolutely minimal safety concerns which have been mitigated through our risk managementprocess. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalentlevel ofenhanced safety, reduced emissions utilizing UAS verses traditional aircraft as well as the economic impact of greatlyreducing the cost ofaerial data and imaging acquisition thereby benefits the greaterpublic's interest. Accordingly, the applicant requests that the FAA grantthe requested exemption without delay.Regulations For Exemption Request Eagle Drone Imaging, LLCrespectfully requests the grant ofan exemption to the following specific sections ofthe Title 14 Code ofFederal regulations allowing itto operate lightweight UASs for commercial use:

Regulation BriefDescription

14 CFR 21, subpart H Air Worthiness Certificates
14 CFR 45.23 (b) Identification and Registration Marking
14 CFR 91.7 (a) Civil AircraftWorthiness
14 CFR 91.9 (b) (2) Civil aircraft flight manual, marking, and placard requirements
14 CFR 91.103 (b) Preflight action
14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight
tests
14 CFR 91.119 Minimum safe altitudes
14 CFR 91.121 Altimeter settings
14 CFR 91.151(a) Fuel requirements for flight in VFR conditions
14 CFR 91.203(a) &(b) Civil Aircraft: Certifications required
14 CFR 91.405(a) Maintenance required
14 CFR 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration.
14 CFR 91.409(a)&(b) Inspections

Amore detailed request for regulation exemptions is provided in AppendixAbelow.

Operational Risk Management: Conditions and Limitations

The following are ourproposed procedures and limitations for the flight operations of Eagle Drone Imaging, LLC. These proposed guidelines will be modified as such from recommendations provided bythe FAA in conjunction with the submission of this request:

1. Flights will only occur during the daytime hours. 2. Flights will be operated in the visual line-of-sight (VLOS) ofthe operator (PIC) and the visual observer (VO) using human vision with no supplemental devices otherthan corrective lenses. 3. Flights will be terminated atanytime the weather and wind deteriorate to being "unsafe for flight" based on manufacturers recommendations and the PIC's experience. Operations will follow the anticipated guidelines ofthisexemption (operations undervisual meteorological conditions-VMC, and standard visual flight rules-VFR) 4. All documents, manuals and maintenance logs associated with the UAS will be present on the site ofoperations. In addition, the credentials ofthe PIC (pilot certificate, pilotlogbookwith currentflight review, currentmedical, and properidentification) will be available onsite. 5. The UAS will be assessed for airworthiness bythe PIC priorto each flight session using a checklist derived from the manufacturers manual. All necessary calibrations and testingprior to the flight session will be performed. 6. The UAS will weigh less than 55 lbs. with speeds well less than 87 knots. 7. Flights will be operated at400 feet AGL orless, or as defined from the
outcome ofthis requestfor exemption. 8. Crewwill be at a minimum ofthe operator (PIC) and an observer and/or

camera operator (VO). The PIC will be responsible for flying the UAS and monitoringits status and flight dynamics, while maintaining line ofsight visualization and keeping the system operations within the specified factory limits (e.g. flight range, batterypower, etc.). The VO will be involved in monitoring the airspace for other aircraft, the ground for unintended vehicles and bystanders, and will also look for additional hazards that could compromise safe operations. 9. Operator (PIC) and crew, including the VO will remain in voice contact duringthe entire flight operation 10. Priorto operations, weather forecasts, weatherradar, and airtraffic patterns for the area will be reviewed. The proximity ofthe intended location with respectto airports and TFRs will be determined using Foreflight software on ouriPad or mobile phones. Ifoperations are anticipated within 5 nautical miles ofairportreference points, the airport management orAir Traffic Control (ATC) towerwill be notified prior to the operation, identifying the location, anticipated time, and the intent of flight operations. We will also have available a hand-held portable radio to enable monitoring oflocal air traffic and to establish, ifnecessary, communicationwith the local tower. When in the vicinity ofnon-towered airports, we will monitor airtraffic in the area and be able to inform them ofour operations as needed. 11. The UAS PIC will perform a final check ofthe flight area and make certain ofthe safety ofall persons presentand propertyin the controlled area priorto initiating flight operations. 12. All UAS will have the capabilityto return automatically to the operator in a safe manner in the event oflostRC communication or a system problem. The auto-return function will be checked and verified for proper operation

on a regular basis. Astarting GPS home-position will be established prior
to continuing each new flight. 13. The UAS will have indicators on the control and/or displays to inform the operator ofthe UAV's distance away from the operator, its altitude and velocity, and its remaining batterypower.14.Written and/or oral permission from the relevantpropertyholders will be obtained when flights are conducted over private or controlled access property.



### Benefits to the Public 

### as a Whole
Approval ofthese 333 exemptions in general would allow commercial operations ofsmall UAS to provide numerous services thatwould benefit from aerial imaging and data collection while greatly enhancing safetyby reducing the overall risk associated with traditional aircraft. Traditional aerial imaging requires large aircraft, such as helicopters, with flammable fuel to fly in close proximity ofpopulated areas and people and often in sub-optimal states of their height-velocity curves. With the use ofsmall UAS of55 lbs. orless that

are battery operated and flying below 400 feet AGL, the risk ofinjury ofpeople

on the ground orthe crew is greatly minimized in comparison. The granting of the use ofthese small UAS by

### Eagle Drone Imaging, LLCwill allow companies like ours to grow and provide career opportunities while also enabling safe and beneficial free enterprise services thatwould assist other companies in their business and also provide enjoyment and information to the general public.


### Eagle Drone Imaging, LLCrespectfully requests the FAA grantits exemption without delay. The FAA has the authorityto issue the exemption soughtby 

### Eagle Drone Imaging, LLCpursuantto the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Please contactme ifl can provide additional information and clarity to help expedite the process.

Eagle Drone Imaging, LLC 11 Ascot Park Nashua, NH 03063 Daltobelli1@mac.com Cell603-305-7705

Commercial Pilot Rotorcraft-Helicopter Certificate Number: 3358875 (20 Nov 2010)

### AppendixA: Regulations for Requested Exemption

Regulation Code Brief Regulation Description Justification for Regulation Description Exemption 14 CFR21, Air Subpart H, entitledAirworthiness Given the size, weight and defined subpartH, Worthiness Certificates, sets forth requirements area ofoperations for Eagle Drone 14 CFR §91.203 Certificates for procurement ofnecessary Imaging, LLC UAS flights permits (a) (1) airworthiness certificates in relation exception from Part 21 because they
to FAR §91.203(a)(1). meet an equivalentlevel ofsafety pursuantto Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirementunder both the Act (49 USC 4470(f) and Section 333 ofthe Reform Act. Both pieces of legislation permitthe FAA to exempt UASs from airworthiness certificates in consideration ofweight, size, speed, maneuverability and proximityto areas such as airports and dense populations. The UAS to be operated are less than 55 lbs. fully loaded, carry neither pilot nor passenger, carry no explosive materials or flammable fuels, and operates within a secured controlled area. Operations under this exemption will be tightly controlled and monitored to ensure safe operations.

14 CFR §45.23 Marking of The regulation requires: When Even though the UAS will have no (b) Aircraft marks include only the Roman airworthiness certificate, an capital letter "N" andthe exemption maybe needed as the registration number is displayed on UAS will have no entranceto the limited, restricted orlight-sport cabin, cockpit orpilot station on categoryaircraft or experimental or which the word Experimental" can provisionally certificated aircraft, be placed. Given the size ofthe UAS, the operator must also display on two-inch letteringwill notbe thataircraftnear each entrance to possible. The word "Experimental" the cabin, cockpit, orpilot station, in will be placed on the fuselage in letters not less than 2 inches nor compliance with §45.29 (f). The

more than 6 inches high, the words equivalentlevel ofsafetywill be "limited," "restricted," "light-sport," provided byhavingthe UAS marked "experimental," or "provisional," as on its fuselage as required by §45.29 applicable. (f) where the pilot, observer and others workingwith the UAS will see the identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A. If required, the Nregistration number will also be displayed on the fuselage in a font size appropriate for the dimension ofthe device for identification purposes.

14 CFR §91.7 (a) Civil Aircraft The regulation requires that no Given the size ofthe aircraft and theWorthiness person may operate a civil aircraft requirements contained in the unless it is in airworthy condition. Manufacturers Operating Manual for As there will be no airworthiness maintenance and use ofsafety certificate issued for the aircraft, checklists prior to each flight, an should this exemption be granted, equivalentlevel ofsafetywill be

no FAA regulatory standard will provided. exist for determining airworthiness.

14 CFR §91.9 (b) Civil aircraft No person may operate a U.S.- The UAS, given its size and (2) flight manual registered civil aircraft

... (2) For configuration has no ability orplace which anAirplane or Rotorcraft to carry such a flight manual on the Flight Manual is notrequired by aircraft, not onlybecause there is no §21.5 ofthis chapter, unless there is pilot on board, butbecause there is available in the aircraft a current no room or capacityto carry such an approved airplane or Rotorcraft item on the aircraft. Flight Manual, approved manual The equivalent level ofsafetywill be material, markings, and placards, or maintained by keeping the flight any combination thereof. manual atthe ground control point where the pilotflying the UAS with immediate access to it. The FAA has issuedthe following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299,9299A, 9565,9565B,10167,10167A, 10602, 32827, and 10700.

14 CFR §91.103 Preflight This regulation requires each pilot Flight information such as runway (b) action in command become familiar with distances and flight performance are all information concerning that notrelevantto the operation ofUAS. flight including runway distances The equivalent action is thatthe PIC and takeoffand landing distances, will review airspace considerations, with this data provide in FAA weather, flight battery requirements, approved rotorcraft flight manuals land and propertyboundaries with will notbe provided for the aircraft respect to takeoffand landing

an exemption will be needed. locations. Manuals for the UAS will present on site ofall operations.

14 CFR §91.109 Flight This section provides that no person UAS are remotelypiloted aircraft, by instruction; may operate a civil aircraft (except a their design do nothave fully Simulated manned free balloon) that is being functional dual controls. Flight instrument used for flight instruction unless control is accomplished through the flight and that aircrafthas fully functioning use ofa control box that certain flight dual controls. communicates with the aircraftvia
tests radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalentlevel ofsafety

can be achieved as neither a pilot

nor passengers will be carried in the aircraft in addition to the small size and low speed ofthe aircraft.

14CFR§91.119 Minimum Section §91.119 establishes safe This exemption is for a UAS that is a safe altitudes altitudes for operation ofcivil RC multi-prop helicopterwith the aircraft. Section §91.119 (d) allows exemption requesting authority to helicopters to be operated atless operate at altitudes up to 400 AGL. than the minimums prescribed, The equivalentlevel ofsafetywill be provided the person operatingthe achieved given the size, weight, andhelicopter complies with any route speed ofthe UAS as well as the

or altitudes prescribed for location where itis operated. No helicopters by the FAA. flight will be takenwithout the permission ofthe property owner or local officials.

14 CFR §91.121 Altimeter This regulation requires each The UAS typically maynothave a settings person operating an aircraftto barometric altimeter, butinstead a maintain cruising altitude by GPS altitude read out, an exemption reference to an altimeter that is set maybe needed. An equivalentlevel "

...to the elevation ofthe departure ofsafetywill be achieved bythe airport or an appropriate altimeter operator, pursuantto the Manual setting available before departure." and Safety Check list, byreceiving altitude information via a digitally encoded telemetric data feed, which downlinks from the aircraftto a ground-based on-screen display. This altitude information will be generatedby equipmentinstalled on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, orradio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation pointwill be established, recorded and confirmed for accuracybythe pilot.

14CFR Fuel Section §91.151 (a) prohibits an The batterypowering the UAS §91.151(a) requirements individual from beginning "a flight provides approximately 20 minutes for flight in in an airplane underVFR conditions ofpowered flight. To VFR unless (considering wind and meetthe 30 minute reserve conditions forecast weather conditions) there requirement in 14 CFR §91.151, UAS is enough fuel to fly to the first point flights would notbe practical. Given ofintended landing, and, assuming the limitations on the UAS's normal cruising speed- (1) During proposed operations are within the the day, to fly after that for atleast "line-of-sight" distances, flight 30 minutes; or (2) At night, to fly durations will instead be determined after thatfor atleast 45 by remaining batterylife. minutes." Telemetry indicators provide indication ofremaining batterylife. At 2 5 percentremaining batterylife, the sequence to bring operations to completion will be initiated. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745,10673, and 10808.

14CFR Civil Aircraft: The regulation provides in pertinent The UAS fully loaded weighs no §91.203(a) &(b) Certifications part: more than 55 lbs. and is operated required (a) Except as provided in§ 91.715, without an onboardpilot. As such,

no person may operate a civil there is no ability or place to carry aircraftunless ithas within itthe certification and registration following: documents orto display them on the (1) An appropriate and current UAS. An equivalentlevel ofsafety airworthiness certificate

.. will be achieved bykeeping these (b) No person may operate a civil documents atthe ground control aircraft unless the airworthiness pointwhere the pilot flying the UAS certificate required by paragraph will have immediate access to them, (a) ofthis section or a special flight to the extentthey are applicable toauthorization issued under §91.715 the UAS. The FAA has issued is displayed atthe cabin or cockpit numerous exemptions to this
entrance so that itis legible to regulation. A representative sample passengers or crew. ofother exceptions includes Exemption Nos. 9565,9665, 9789, 9789A,9797,9797A,9816A,and 10700.

14CFR Operation These regulations require that an Given thatthese sections and Part43 §91.405(a) after aircraft operator or owner "shall apply onlyto aircraftwith an §91.407(a)(1) maintenance, have that aircraftinspected as airworthiness certificate, these §91.409(a)&(b) preventive prescribed in subpartEofthis part sections will not applyto the maintenance, and shall between required applicant. The operatorpursuantto rebuilding, or inspections, except as provided in the flight manual and operating alteration. paragraph (c) ofthis section, have handbookwill accomplish discrepancies repaired as maintenance. Software and firmware prescribed in part43 ofthis will be maintained with current chapter

...," and others shall inspect versions. As the manufacturer does

or maintain the aircraft in notprovide specific maintenance compliance with Part43. instructions, maintenance will be "on condition" for all aircraft and each aircraftwill have a maintenance log.

References Part 91 weblink General Operating and Flight Rules Part45 weblink Identification and Registration Marking Petitioning weblink for Exemption Under Section 333