May 15, 2015

FAA Petition for exemption 14 CFR 11.81

William Benton Henry

Benton Henry Photography L.L.C.

224 East Bamberg Street

Latta, South Carolina 29565

- 1603

USA

Phone: 843

- 752

- 9999

Email: Benton@BentonHe nry.com

Seeking Exemption for: 14 CFR part 21, Certification procedures for products and

parts, Subpart H

— Airworthiness Certificates

.

Purpose for Exemption: Very low

- level aerial photography and aerial videography

for the purpo se of marketin g and inspections that cannot be

accomplished from traditional aircraft.

Benefit to the Public:

Safety:

The exemption would allow low

- level photography work

that is a much greater danger when performed by traditional fix

wing and/ or rotor

- wing craft

- to both the occupant s of the

aircraft and the general public on the ground in the area of the

work.

The lower flight levels of traditional aerial photography are

more dangerous because the ability to recover from

stall s and/or loss of power

. Fixed

- wing aircraft require altitude

to recover from a stall and rotorcraft requires a ltitude to perform

an auto

- rotation to recover from a loss of power

. Traditional

aerial photography generally operate v ery c lose to the limits of

stall / recovery.

Aerial photography flights also add to the burden of ATC

– these types of flights usually involve flying in circles

around the subject area and require the attention of flight

controll ers and other pilots flying in the same area.

Traditional aircraft have minimums altitudes around

structures

– generally 1000 AGL

– (much higher than is

required for the type of work I need to perform.

Much of my architectural photogr aphy work could be done

below 200 feet AGL , which is not possible from either

fixed or rotor

- wing.Nuisance:

T raditional aircraft are much nosier

– and while not a safety

issue can be a nuisance issue to the general public.

Exemption not affecting

Safety: My work is done for purpose of showing structures and is

performed generally without any people around never

directly over people. Work would be done during daylight

hours and always line of sight. As stated earlie r my work

would be performed less than 200 feet AGL

. I have also

adopted a industry standard Pre

- flight, flight, and post

flight plan and a procedure for logging each flight. All

equipment meets legal requirement for usage in the US

–

inclu ding compliance with FCC for radio frequency

controls.

Summary: William Benton Henry as the sole owner/operator of

Benton Henry Photography is asking for an exemption to

14 CFR part 21, Certification procedures for products and

parts, Subpart H

— Airworthiness Certificates for the

p urpose of low level (less than 200 feet AGL)

photography/videography as part of my commercial

photography business. Photography subjects to include

structures and surrounding areas for the purposes of

marketing. The exemption would help reduce the chances

of injury to pilot and photographer and general public in the

area of the photo sites. The exemption would also greatly

reduce the chances of catastrophic property damage.

UAS proposed for use: DJI Inspire, D JI phanto m, DJI Spreading Wings,

Yuneec Q500.

Additional Information: I have worked as a commercial aerial photographer for over

20 years. I have training as a traditional fix wing pilot

including over 40 hours as Pilot in Command (student).

I have adopted a pre

- flight

– flight

– and post

- flight plan

for UAS (drone) operations if approved.

Respectfully Submitted,William Benton Henry

Mailed to:

U.S. Department of Transportation,

Docket Operations

West Building Ground Floor,

Room w1 2

- 140

1200 New Jersey Avenue, SE.,

Washington, DC 2059 0