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 Of Transportation 

Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., Washington, DC 20590 

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

ofthe Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

reform act) and 14 CFR Part 11, Eagle Drone Imaging, LLC, a company that 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, 

LLC may operate UAS commercially in airspace regulated by the FAA, as long as such 

operations are conducted within and under the conditions outlined herein or as 

maybe established by the FAA as required by 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 current medical 

certificate and flight review, and nearly 320 hours as PIC. He also has an estimated 

25 hours of experience flying UAS and is familiar with the operations and the 

maintenance of the hardware and software updates for these systems. 

Operations will involve collection of aerial imaging and sensor data to enable 

inspections and assessments of industrial structures, agricultural management and 

surveys, and photography and videography (e.g. land and water based venues for 

imaging real-estate, naturaljscenic settings, outings, functions and events). 

Equivalent Level of Safety 

The requested exception would permit the operation of a lightweight (less than 55 

lbs. total takeoff weight) UAS under controlled conditions for commercial use by a 

certified commercial helicopter pilot thereby enhancing safety and fulfilling the 

Secretary of Transportation's (the FAA Administrator's) responsibility to" establish 

requirements for safe operation of such aircraft systems in national airspace 
systems", Section 333 (c) of the Reform Act. The enhanced safety using a UAS in 

comparison to a manned aircraft, including helicopters of significantly greater 

proportion and carrying a crew with flammable fuel is self-evident and beneficial to 

the public's interest, while being able to provide commercially beneficial 

information and data more quickly, accurately, safely and economically with 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 right to privacy safeguarded at all times. 

UAS Devices 

Eagle Drone Imaging's UAS(s) are battery-powered, weighing well less than 55 

pounds including payload. Our UAS fleet will include the DJI Phantom Series, the DJI 

Inspire Series, and the Spreading Wings Series of RC multi-prop helicopters. The 

specific UAS(s) to be initially included in our fleet: 

Parameter DJI Phantom 2 DJI Inspire 1 Spreading Wings 

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 (max 1 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 capability to hover and 

move in the vertical and horizontal planes simultaneously in a precisely controlled 

manner. Our primary intent is to utilize them at much slower speeds for our imaging 

and data collection applications. As upgrades become available, we would 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. 

Statutory Authority for Exemptions 

Eagle Drone Imaging, LLC submits this application in accordance with the Reform 

Act, 112 P.L. 95 331-334, seeking relief from any currently applicable FAR'S 

operating to prevent Eagle Drone Imaging, LLC from future commercial use of small 

UAS to operate in the national airspace system as described below. The reform Act 

section 332 provides for such integration of civil unmanned aircraft into our 

national airspace system as it is in the public's interest to 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 of these UAS are expressly 

contemplated by the Reform Act. Eagle Drone Imaging, LLC would like to operate its' 

light weight UAS( s) prior to the time period by which the Reform Act requires the 

FAA to promulgate rules governing such aircraft. 

The Reform Act directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in national airspace before 

completion of the rule making required under Section 332 of the reform Act. In 
making this determination, the Secretary of Transportation is required to determine 

which UAS do create a hazard to users of the national airspace system or the public 

or pose a threat to national security in light of the following: 

-The UAS size, speed, weight and operational capability 

- Operation of the UAS in close proximity to airports and populated areas 

-Operation of the UAS within visual line of sight of the operator 

Reform Act 333(a). If the 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, LLC utilizes 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 only within the visual 

line-of-sight of the operator within a controlled flight area and at 400 feet 

above ground level (AGL) or less. Most operations are envisioned at less than 

100 feet AGL. These will not present a hazard to the national airspace nor 

the public. 

The very small nature of these UAS combined with the risk management 

presented below, will allow for the safe operation greater than that 

envisioned by Congress for the FAA to establish and by exemption allowing 

commercial operations of UAS to commence immediately. Also due to the 

size of UAS and the controlled areas and the low altitudes in which they will 

operate, approval of this exemption presents no national security issues and 

absolutely minimal safety concerns which have been mitigated through our 

risk management process. Given the clear direction given in Section 333 of 

the Reform Act, the authority contained in the Federal Aviation Act, as 

amended, the strong equivalent level of enhanced safety, reduced emissions 

utilizing UAS verses traditional aircraft as well as the economic impact of 

greatly reducing the cost of aerial data and imaging acquisition thereby 

benefits the greater public's interest. Accordingly, the applicant requests that 

the FAA grant the requested exemption without delay. 
Regulations For Exemption Request 

Eagle Drone Imaging, LLC respectfully requests the grant of an exemption to the 

following specific sections of the Title 14 Code of Federal regulations allowing it to 

operate lightweight UASs for commercial use: 

Regulation Brief Description 

14 CFR 21, subpart H Air Worthiness Certificates 

14 CFR 45.23 (b) Identification and Registration 

Marking 

14 CFR 91.7 (a) Civil Aircraft Worthiness 

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 

A more detailed request for regulation exemptions is provided in Appendix A below. 

Operational Risk Management: Conditions and Limitations 

The following are our proposed procedures and limitations for the flight operations 

of Eagle Drone Imaging, LLC. These proposed guidelines will be modified as such 

from recommendations provided by the 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) of the operator 

(PIC) and the visual observer (VO) using human vision with no 

supplemental devices other than corrective lenses. 

3. Flights will be terminated at any time 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 of this 
exemption (operations under visual 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 of operations. In addition, the credentials of the PIC 

(pilot certificate, pilot logbook with current flight review, current medical, 

and proper identification) will be available onsite. 

5. The UAS will be assessed for airworthiness by the PIC prior to each flight 

session using a checklist derived from the manufacturers manual. All 

necessary calibrations and testing prior 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 at 400 feet AGL or less, or as defined from the 

outcome of this request for exemption. 

8. Crew will be at a minimum of the operator (PIC) and an observer and/or 

camera operator (VO). The PIC will be responsible for flying the UAS and 

monitoring its status and flight dynamics, while maintaining line of sight 

visualization and keeping the system operations within the specified 

factory limits (e.g. flight range, battery power, 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 

during the entire flight operation 

10. Prior to operations, weather forecasts, weather radar, and air traffic 

patterns for the area will be reviewed. The proximity of the intended 

location with respect to airports and TFRs will be determined using 

Foreflight software on our iPad or mobile phones. If operations are 

anticipated within 5 nautical miles of airport reference points, the airport 

management or Air Traffic Control (ATC) tower will 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, if necessary, 

communication with the local tower. When in the vicinity of non-towered 

airports, we will monitor air traffic in the area and be able to inform them 

of our operations as needed. 

11. The UAS PIC will perform a final check of the flight area and make certain 

of the safety of all persons present and property in the controlled area 

prior to initiating flight operations. 

12. All UAS will have the capability to return automatically to the operator in a 

safe manner in the event oflost RC communication or a system problem. 

The auto-return function will be checked and verified for proper operation 

on a regular basis. A starting 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 of the UAV's distance away from the operator, its altitude and 

velocity, and its remaining battery power. 
14. Written and/or oral permission from the relevant property holders will be 

obtained when flights are conducted over private or controlled access 

property. 

Benefits to the Public as a Whole 

Approval of these 333 exemptions in general would allow commercial 

operations of small UAS to provide numerous services that would benefit from 

aerial imaging and data collection while greatly enhancing safety by 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 of populated areas and people and often in sub-optimal states of 

their height-velocity curves. With the use of small UAS of 55 lbs. or less that 

are battery operated and flying below 400 feet AGL, the risk of injury of people 

on the ground or the crew is greatly minimized in comparison. The granting of 

the use of these 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 that would assist other companies in 

their business and also provide enjoyment and information to the general 

public. 

Eagle Drone Imaging, LLC respectfully requests the FAA grant its exemption 

without delay. The FAA has the authority to issue the exemption sought by 

Eagle Drone Imaging, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 

(1958) as amended (the ACT). 

Please contact me ifl can provide additional information and clarity to help 

expedite the process. 

Eagle Drone Imaging, LLC 

11 Ascot Park 

Nashua, NH 03063 

Dalto belli 1 @mac.com 

Cell603-305-7705 

Commercial Pilot Rotorcraft-Helicopter 

Certificate Number: 3358875 (20 Nov 2010) 
Appendix A: Regulations for Requested Exemption 

Regulation Code Brief Regulation Description Justification for Regulation 

Description Exemption 

14 CFR21, Air Subpart H, entitled Airworthiness Given the size, weight and defined 

subpartH, Worthiness Certificates, sets forth requirements area of operations for Eagle Drone 

14 CFR §91.203 Certificates for procurement of necessary 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 equivalent level of safety 

pursuant to Section 333 ofthe 

Reform Act. The FAA is authorized to 

exempt aircraft from the 

airworthiness certificate 

requirement under both the Act ( 49 

USC 4470(f) and Section 333 of the 

Reform Act. Both pieces of 

legislation permit the FAA to exempt 

UASs from airworthiness certificates 

in consideration of weight, size, 

speed, maneuverability and 

proximity to 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" and the exemption may be needed as the 

registration number is displayed on UAS will have no entrance to the 

limited, restricted or light-sport cabin, cockpit or pilot station on 

category aircraft or experimental or which the word Experimental" can 

provisionally certificated aircraft, be placed. Given the size of the UAS, 

the operator must also display on two-inch lettering will not be 

that aircraft near each entrance to possible. The word "Experimental" 

the cabin, cockpit, or pilot 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 equivalent level of safety will be 

"limited," "restricted," "light-sport," provided by having the UAS marked 

"experimental," or "provisional," as on its fuselage as required by §45.29 

applicable. (f) where the pilot, observer and 

others working with the UAS will see 

the identification of the 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 N registration 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 of the aircraft and the 
Worthiness 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 of safety 

certificate issued for the aircraft, checklists prior to each flight, an 

should this exemption be granted, equivalent level of safety will 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 or place 

which an Airplane or Rotorcraft to carry such a flight manual on the 

Flight Manual is not required by aircraft, not only because there is no 

§21.5 ofthis chapter, unless there is pilot on board, but because there is 

available in the aircraft a current no room or capacity to carry such an 

approved airplane or Rotorcraft item on the aircraft. 

Flight Manual, approved manual The equivalent level of safety will be 

material, markings, and placards, or maintained by keeping the flight 

any combination thereof. manual at the ground control point 

where the pilot flying the UAS with 

immediate access to it. The FAA has 

issued the 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 not relevant to the operation of UAS. 

flight including runway distances The equivalent action is that the PIC 

and takeoff and landing distances, will review airspace considerations, 

with this data provide in FAA weather, flight battery requirements, 

approved rotorcraft flight manuals land and property boundaries with 

will not be provided for the aircraft respect to takeoff and landing 

an exemption will be needed. locations. Manuals for the UAS will 

present on site of all operations. 

14 CFR §91.109 Flight This section provides that no person UAS are remotely piloted aircraft, by 

instruction; may operate a civil aircraft (except a their design do not have 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 aircraft has fully functioning use of a control box that 

certain flight dual controls. communicates with the aircraft via 

tests radio communications. The FAA has 

approved exemptions for flight 

training without fully functional dual 

controls for a number of aircraft and 

for flight instruction in experimental 

aircraft. See Exemption Nos.5778K & 

9862A. The equivalent level of safety 

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 of civil RC multi-prop helicopter with the 

aircraft. Section §91.119 (d) allows exemption requesting authority to 

helicopters to be operated at less operate at altitudes up to 400 AGL. 

than the minimums prescribed, The equivalent level of safety will be 

provided the person operating the achieved given the size, weight, and 
helicopter complies with any route speed of the UAS as well as the 

or altitudes prescribed for location where it is operated. No 

helicopters by the FAA. flight will be taken without the 

permission ofthe property owner or 

local officials. 

14 CFR §91.121 Altimeter This regulation requires each The UAS typically may not have a 

settings person operating an aircraft to barometric altimeter, but instead a 

maintain cruising altitude by GPS altitude read out, an exemption 

reference to an altimeter that is set may be needed. An equivalent level 

" ... to the elevation ofthe departure of safety will be achieved by the 

airport or an appropriate altimeter operator, pursuant to the Manual 

setting available before departure." and Safety Check list, by receiving 

altitude information via a digitally 

encoded telemetric data feed, which 

downlinks from the aircraft to a 

ground-based on-screen display. 

This altitude information will be 

generated by equipment installed on 

board the aircraft, using GPS 

triangulation, or digitally encoded 

barometric altimeter, or radio 

altimeter, or any combination 

thereof. Prior to each flight, a zero 

altitude initiation point will be 

established, recorded and confirmed 

for accuracy by the pilot. 

14CFR Fuel Section §91.151 (a) prohibits an The battery powering the UAS 

§91.151(a) requirements individual from beginning "a flight provides approximately 20 minutes 

for flight in in an airplane under VFR conditions of powered flight. To 

VFR unless (considering wind and meet the 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 not be practical. Given 

of intended 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 at least "line-of -sight" distances, flight 

30 minutes; or (2) At night, to fly durations will instead be determined 

after that for at least 45 by remaining battery life. 

minutes." Telemetry indicators provide 

indication of remaining battery life. 

At 2 5 percent remaining battery life, 

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 onboard pilot. As such, 

no person may operate a civil there is no ability or place to carry 

aircraft unless it has within it the certification and registration 

following: documents or to display them on the 

(1) An appropriate and current UAS. An equivalent level of safety 

airworthiness certificate .. will be achieved by keeping these 

(b) No person may operate a civil documents at the ground control 

aircraft unless the airworthiness point where the pilot flying the UAS 

certificate required by paragraph will have immediate access to them, 

(a) ofthis section or a special flight to the extent they are applicable to 
authorization issued under §91.715 the UAS. The FAA has issued 

is displayed at the cabin or cockpit numerous exemptions to this 

entrance so that it is legible to regulation. A representative sample 

passengers or crew. of other exceptions includes 

Exemption Nos. 9565,9665, 9789, 

9789A,9797,9797A,9816A,and 

10700. 

14CFR Operation These regulations require that an Given that these sections and Part 43 

§91.405(a) after aircraft operator or owner "shall apply only to aircraft with an 

§91.407(a)(1) maintenance, have that aircraft inspected as airworthiness certificate, these 

§91.409(a)&(b) preventive prescribed in subpart E of this part sections will not apply to the 

maintenance, and shall between required applicant. The operator pursuant to 

rebuilding, or inspections, except as provided in the flight manual and operating 

alteration. paragraph (c) of this section, have handbook will accomplish 

discrepancies repaired as maintenance. Software and firmware 

prescribed in part43 of this will be maintained with current 

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

or maintain the aircraft in not provide specific maintenance 

compliance with Part 43. instructions, maintenance will be 

"on condition" for all aircraft and 

each aircraft will have a 

maintenance log. 

References Part 91 we blink 

General 

Operating 

and Flight 

Rules 

Part45 we blink 

Identification 

and 

Registration 

Marking 

Petitioning we blink 

for 

Exemption 

Under 

Section 333