Naim Hasan Photography, LLC 6405 NE Cleveland Ave Portland, OR 97211 503-421-7493 naim@n2htec.com

Date: July 25, 2015

Submitted To:

US Department of Transportation Federal Aviation Administration 800 Independence Ave SW Washington, D.C.20591

RE: Petition for Exemption 14 CFR 11.81

Dear Sir or Madam:



### Company Overview

Naim Hasan Photography, LLC, located at 6405 NE Cleveland Ave., Portland, OR 97211, has been providing digital photographic services to a diverse group of Local, National, Private and Public organizations, since 2002. With the introduction of aerial photography/video services, those same organizations will be provided cost effective options that will improve the quality and type of visual information which in many cases will help to reduce cost and increase the accuracy in their decision making processes.

NHP is State of Oregon certified as a Minority Business Enterprise (MBE), Emerging Small Business (ESB) and Disadvantaged Business Enterprise (DBE) # 7242, expiring March 2018. In January 2015, I received the Trusted Traveler Global Entry number# 984960548 provided by the Transportation Security Administration (TSA).

NHP’s wishes to deploy for commercial operations the DJI Inspire 1, T600 Quad-rotor Unmanned Aircraft System (UAS): (See below for the overview of the DJI Inspire 1, T600 Quad-rotor Unmanned Aircraft System)



### Proposed uses for the UAS

*Aerial photography and/or video for public and/or private use including: real estate, real estate inspection, architecture, engineering and other related professional activities. *Land development/ surveying documentation and commercial construction *Documentation of natural fish and wildlife habitats (Logjams)*Inspection of cellular towers, utility poles and other structures accessible by aerial views. *Aerial photography for marketing and advertising used in print and Web based mediums.



### DJI Inspire 1 Overview

The DJI Inspire 1, T600 is a quad-rotor Unmanned Aircraft System (UAS), fully self contained unit including onboard battery power, and weighs less than seven (7) pounds. This UAS come equipped with an on-board camera which supports 4K video capture up to 4096 x 2160p24 and 12M pixel photos captured by using the 1/2.3 in CMOS sensor. The 3-axis Gimbal technology provides a steady platform for the attached camera, allowing for the capture of stabilized images and video. The Gimbal can tilt the camera up 120 degrees and rotate 360 degrees.

This unit is not designed to carry additional payload making it environmentally safe and economically advantageous to share the NAS. The Inspire 1 is controlled by a mobile ground station (Controller) which connects to a smart phone or smart tablet. The DJI Inspire 1 has a special pilot app that must be downloaded to the phone or tablet which fully integrates with the UAS providing visual control and access to the features of the UAS. This user interface offers valuable GPS information transmitted from the UAS back to the controller, which is displayed on the smart device offering 720p HD view of everything the camera sees. With this detailed information at the operators disposal, flying becomes extremely safe and reduces the potential danger to people and the environment. The UAS come equipped with a programmable Safety Return To Home function that can be activated due to low battery power, or loss of radio connection between the UAS and the controller. Manual Return To Home can be activated anytime based on the operators preference.



### Exemption Request

This petition is based, in part on prior exemptions granted by the FAA who’s exemption numbers are as follow: 11410, 12042, 12097, 12115, 12116.

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (the “Reform Act”) and Title 14 of the Code of Federal Regulations (CFR) , Naim Hasan Photography, LLC, referred to as (NHP) owner and operator of the above mentioned DJI Inspire 1, Model T600, Unmanned Aircraft System (UAS), request exemption from the Federal Aviation Regulations (FAR) listed below which would allow NHP the privilege of operating the above mentioned UAS commercially in the airspace regulated by the FAA., so long as, operation of the aforementioned UAS is conducted within and under the conditions and safety guidelines outlined herein or as maybe established by the FAA as required by Section 333.NHP request exemption from Title 14 of The Code of Federal Regulations (CFR) Sections: Part 21 Subpart H; ( Certification); 45.23 (b) (N number identification); 61.31 (a); 61.113 (a) and (b) (Flying for Hire); 91.7 (a); 91.9 (b) and (2) (Airworthiness); 91.103 (Preflight, Airport); 91.119; 91:121; 91.151 (a); 91.203 (a) and (b); 91.405 (a); 91.407 (a) (1) and (2); 91.409 (a) (1) and (2); 91.417 (a) and (b).



### The extent of relief NHP is seeking and the reasons we seek such relief

CFR part 21 Subpart H: prescribing the procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approvals. NHP believes that relief from this section is not necessary under the statutory criteria set forth in Section 333 of Public Law 112-95 (P.L. 112-95) in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS.

As of March 23, 2015 the FAA has stated that a “blanket” COA will be automatically granted with a Section 333 exemption when the UAS maintains flights at or under 200 AGL.



### Section 45.23 (b) prescribing that when marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certified aircraft, the operator must also display on the aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited”, “restricted”, “light-sport”, “experimental”, or “Provisional”, as applicable. NHP believes that relief from the section is not necessary as the proposed UAS is not certified under Section 21.191 and this petition is submitted in connection with proposed operation as a Civil UAS.



### Section 61.31 (a) prescribing that a person who acts as a pilot in command of any of the following aircraft must hold a type rating for that aircraft for other aircraft specified by the Administrator through aircraft type certificate procedures: Large aircraft (except lighter-than-air), Turbojet-powered airplanes, and other aircraft specified by the Administrator through aircraft type certificate procedures. NHP believes relief from this section is not warranted under the statutory criteria outlined in Section 333 of P.L. 112-95 in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS. NHP, however, respectfully requests exemption of 

### 61.113 (a) and (b) , and if granted the UAS will fully comply with the qualifications of PIC noted herein.



### Section 91.7 (a) prescribing that no person may operate a civil aircraft unless it meets airworthiness requirements. NHP requests relief from this section because the airworthiness of the UAS will be determined by the operator based on the operationaldocuments provided by the manufacture of the DJI Inspire 1 UAS. NHP will adhere to the following prior to each flight of the UAS mentioned above:

a. NHP will inspect the UAS and Ground control unit to insure both are functioning properly based on the manufacturers operational requirements. b. NHP will follow DJI’s aircraft/component, maintenance schedule, overhaul, replacement, inspection and life limit requirements.

c. NHP will comply with all DJI’s manufacturer safety bulletins.



### Section 91.9 (b)(2) prohibits the operation of a civil aircraft unless there is a aircraft flight manual in the aircraft. Given the size of the UAS and the fact that there is no pilot or passengers onboard the UAS, this regulation does not apply and NHP request that relief be granted.

The FAA has previously issued exemptions to this regulation in Exemption No’s: 8607, 8737, 8738, 9299, 9565, 10167, 10602, and 32827



### Section 91.119 establishes minimum safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at lower altitudes under certain conditions. NHP is requesting relief from this section because flights made by the DJI Inspire 1 UAS will not exceed 400’ AGL. When flying over private property or people, the proper consent documentation and approvals will be obtained prior to the flight. In addition, the low-altitude operation of the UAS will ensure adequate separation between the UAS operations and the operations if conventional aircraft that must comply with Section 91.119.



### Section 91:121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure. NHP request relief from this section because the UAS mentioned in the document does not have a barometric altimeter but instead provides a GPS altitude information that is displayed through the pilot app to the smart phone or tablet. If the UAS exceed an altitude that is outside the limits of the controller and UAS the communications signal weakens and a notification is displayed on the smart device indicating that a lower altitude must be reached in order to maintain control of the UAS or Automatic Return to Home is activated. NHP intends to stay within the flight limits to avoid any potential consequences that would prevent the UAS from landing successfully.



### 91.151 (a) prohibits an individual from beginning 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. NHP is requesting relief from this section due to the fact that the UAS is a battery powered unit with flight times ranging from eighteen (18) minutes of flying time when the TB47 4500m0Ah smart battery is in use and up to twenty-two (22)minutes of flying time when the TB48 smart battery is in use. The Low power indication displays on the smart device notifying the PIC that it is time to return to home.

NHP is requesting exemption from the following sections because they are all associated with airworthiness and the is no airworthiness certification establish for small
UAS’s. 

### 91.203 (a) and (b); 91.405 (a); 91.407 (a) (1) and (2); 91.409 (a) (1) and (2);91.417 (a) and (b). The operator will take every precaution, through preflight planning, to insure that the UAS is functioning to the highest standards possible as outlined by the manufacturer and will fly within the limits outlined in this petition.



### Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should publication of this petition be needed: NHP request exemption from Title 14 of The Code of Federal Regulations (CFR) Sections: Part 21 Subpart H; ( Certification); 45.23 (b) (N number identification); 61.31 (a); 61.113 (a) and (b) (Flying for Hire); 91.7 (a); 91.9 (b) and (2) (Airworthiness); 91.119; 91:121; 91.151 (a); 91.203 (a) and (b); 91.405 (a); 91.407 (a) (1) and (2); 91.409 (a) (1) and (2); 91.417 (a) and (b) with the sole purpose of operating commercially a DJI Inspire 1, T600 Unmanned Aircraft System (UAS). Through the granting of this petition the FAA administrator will be helping to creature and foster small business development and economic opportunities for individuals and businesses. The deployment of UAS’s can provide cost effective alternatives for businesses engaged in research, land use planning and documentation, search and rescue, surveying, inspections of various types including power poles, natural habitats, wind turbines, bridges and other applications. Due to the limited size and operational area, limited speeds, limited battery power, and return to home features, the UAS does not pose a threat to the NAS. NHP once again respectfully request the FAA request exemption to the above mentioned sections without delay.

Thank you very much for your time and consideration.

Sincerely,

Naim Hasan, Owner/Photographer Naim Hasan Photography, LLC!!!