# Petition for Exemption 14 

# CFR § 

# "11.81 

# Exemption petition under SEC 331

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### ·'· } ;-

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# *Your name and mailing address. You may include other contact information such as a fax number, ,telephone number, or email address; Name: Bruce Kist Address:. 44 

# Hami 1ton Dr. Spotswood, NJ 08884 

# Phone: 732 261 0234 

# Email :.,:Brl,lcieiam@aol.com
*The specific section or

**sec~ions** 

# of 14 

# CFR from which you seek an exempt:i'on; Petition for Exemptidn under

**s~c** 

# 3j3 · .· 

# *The extent of relief you seek and the reason you seek the relief;· sec 333 

# prohibits the use 

# bf a UAS for .commercial purposes on private property. I 

# am a professional photographer of 45 years and am simply petitioning for an exemption to provide a commercial service to private land owners and companies who wish to obtain and · capture Aerial photos and videos of said property for purposes including real estate listings, insurance property claims, and for use as a marketing tool for businesses. I 

# would like to be able to accept payment for these services therefore making this a commercial use of a UAS.
*How your request would benefit the public as a whole; My request benefits the public as a whole by providing an opportunity for small business owners, real estate agents, and others who wish to document their land or property to take advantage of the technology that now exists in the form of UAS's and

# allows them to do so safely by using this newest technology.

*Reasons why the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to the existing rule; Being a pilot in training and a AMA R/C pilot in training, I 

# therefore understanding the importance of different uses and safety concerns regarding FAA regulated airspace, I 

# would be a good candidate for exemption of sec 333 while not putting Air safety in any accelerated risk. The specific UAS I 

# will be using is state of the art with GPS guidance, SAFE technology and designed with safety first features. when flying for this commercial purpose I 

# would be flying at a maximum altitude of 125 feet and flying mostly vertically for the purposes of taking photos, decreasing the risk of any interference. My general knowledge of the aviation safety systems implemented by the FAA would be used to ensure that safety would not be affected by my operations. I 

# would not be flying near disaster areas, sporting events, or high traffic areas including airports, and I 

# would pay attention to NOTAMS. I 

# have enclosed information about the unit I 

# will be flying.

I 

# Intend to follow these suggested safety regulations • Always keep aircraft in sight and under control: • Always keep people and pets at least 35 feet (10 meters) away when the battery is connected. • Keep children out of the vicinity of this product at all times. • Always use fully charged batteries. • Always keep transmitter powered on while aircraft is powered. • Always remove batteries before disassembly.

# • Always keep mov1ng parts clean. • Always keep parts dry. • Always let parts cool after use before touching. • Always remove batteries after use. • Always have a first aid kit with you. • Always have an appropriate fire extinguisher with you. • Never operate aircraft with damaged wiring. • Never touch moving parts. *A summary we can publish in the Federal Register Federal Register

- I, 

# Bruce Kist, am seeking an exemption of the FAA's sec 333 rules that does not allow the use of an Unmanned Aircraft to be used for commercial purposes in regards to National Airspace safety. I 

# am simply petitioning for an exemption to provide a commercial service to private land owners and companies who wish to obtain and capture Aerial photos and videos of said · · property for purposes including real estate listings, insurance property claims, and for use as a marketing tool for

**businesse~.** 

# Being

**~** 

# private pilot in training and a AMA R/C pilot in training, I 

# therefore understanding the importance of different uses and safety concerns regarding FAA regulated a1rspace, I 

# would be a good candidate for exemption of sec 333 while not putting Air · safety in any accelerated risk. The specific UAS I 

# am seeking exemption with is one with many safety programs, including SAFE technology and GPS navigating. when flying for this commercial purpose I 

# would be flying at a maximum altitude of 125 feet and flying mostly vertically for the purposes of taking photos, decreasing the risk of any interference. My general knowledge of the aviation safety systems implemented by the FAA would be used to ensure that safety would not be affected by my operations. I 

# would not be flying near disaster areas, sporting events, or high traffic areas including airports, and I 

# would pay attention to NOTAMS. I 

# appreciate the FAA's · · consideration of this petition for exemption.

# *Any additional information, v1ews, or arguments available to support your request; I am fully aware of the pre flight safety checks and procedures and intend to implement pre flight safety checks and utilize the safety technology provided with th1s unit. I intend to only fly in non populated, residential or rural areas and stay clear of all utility lines etc. I intend to be fully aware of my surroundings at all times and to only fly the unmanned aircraft within a visual line of sight and only in Visual Flight conditions. I have enclosed information about the unit I will be flying. I understand and will comply with all the health and safety regulations for PIC's and will be the only operator under this exemption.

General safety Precautions and warnings I

**int~nd** 

# to Follow • Always keep a safe distance in all directions around your model to avoid collisions · · · or injury. This model is controll.ed

**b~** 

# a radio signal subject to interference from many sources outside your control. Interference can cause momentary loss of control. • Always operate your model 1n open spaces away from full-size vehicles, traffi c and people. • Always carefully follow the directions and warnings for this and any optional support equipment (chargers, rechargeable battery packs, etc.).

# " '



# • Always keep all chemicals, small parts and anything electrical out of the reach of children. • Always avoid water exposure to all equipment not specifi cally designed and protected for this purpose. Moisture causes damage to electronics. • Never place any portion of the model in your mouth as it could cause serious injury or even death. • Never operate your model with low transmitter batteries. • Always keep aircraft in sight and under control. • Always move the throttle fully down at rotor strike. • Always use fully charged batteries. • Always keep transmitter powered on while aircraft 1s powered. • Always remove batteries before disassembly • Always keep moving parts clean. • Always keep parts dry. • Always let parts cool after use before touching. • Always remove batteries after use. • Never operate aircraft with damaged wiring. • Never touch moving parts. *If you want to exercise the privileges of your exemption outside the united States, you must state the reason. I have no intention on using this exemption outside the united States

### a,t1C/2G15 DJI Phantom3AdwncedQuadcopterwth 1080pCameraand 3-Axis Gimbal

**~.:**....**~·.f..}........................................................................................................................................................................................................................................................** ........................... ......................... .. !A complete 1080p camera and 3-axis gimbal system come integrated with the Phantom 3 Advanced edition quadcopter \fromDJI. In addition to video,the camera is capable shooting up to 12MP still photos usingJPEG or non-proprietary DNG RAW [format. The three axes ofthe gimbal give you pan and tilt control, and keep the horizon line level even as the aircraft banks. !Different gimbal settings allow the camera to lockonto a fixed subject, be moved manually using transmitter rotaries orthe japp, orto simply provide camera stabilization.



# ~his bundle ofthe Phantom

### 3 is classed as "ready-to-fly." This means the basics to get you in the airare included 

### -a flight !battery,charger, and pre-bound handheld transmitter (radio controller) among them. Depending on you application,you may !also require a microSD memory card for in-camera recording, additionalflight batteries, and a mobile device to access the app, !and possibly otheraccessories. Also note that a numberofimportant compass and GPS calibration steps must be carried out !before flying to ensure the flightcontrol computeroperates correctly. Please referto the manual or Quick Start Guide before jyourfirstflight.



# ~Phantom 3 FlightControl System !Main Controller \The burden ofprocessing and analyzingflightdata in real time ittaken up bythe Main Controller,the brains ofthe !computerized flight control system. Itcollects data fromthe entire system, including motorspeed, GPS location,yourcommand [inputs, and data fromautomatic sensors, and analyzes it all to tellyour Phantom 3 exactly how to behave at any given [moment ',GPS Navigation jBecause ofthe complexityassociated with multi-rotoraircraftthe Phantom 3 relies on a GPS-based navigation systemto !maintain flightstabilityand provide otherfeatures. While fully manual operation is possible, most users, especially ivideographers hoping to getthe smoothest possible shoots,will optforone ofthe GPS-assisted modes liMU



# ~he Inertial Measurement Unit (IMU) uses a 6-axis gyroscope plus an accelerometerto keep trackthe slightesttilt orchange [in acceleration.This data is relayed to the Main Controllerand used to help maintain a stable flight ! iESCs [Four Electronic Speed Controllers (ESCs) not only relay vital motorspeed information to the Main Controller,they also send [commands backto the motors based on your input.This constant communication helps keeps your Phantom 3stable in flight, 'and also helps you achieve anyflight movement, from gentle pans to rapid acceleration Vision Positioning Systemfor Indoor Navigation :Vision Positioning System uses a speciallydesigned camera as well as sonicwaves to provide comparable stabilityfunction !indoors ordose to the ground as GPS does outdoors.This technology allows the Phantom 3 to hold its location,stop when lthe controls are released, and quickly respond to pilot commands even when GPS is unavailable Auto-Takeoff [With one tap in the DJI Pilot app,the Phantom 3 will turn on its motors and raise to a pre-set height. Itwill then hover in [place, completely motionless until you direct itwhere to go jAuto-Landing !when GPS is available, the Phantom 3 remembers the exact spotthat ittookoff. Simply tap a button to have it return to the !poinffrom which ittookoff !Return to Home Failsafe lrfthe Quadcopterloses the signal fromthe controllerforany reason orthe battery starts to run low the "return to home" !feature will initialize. The aircraftwill ascend to 60 feetthen make a straight-line course backto the "home position" you will ,have defined during the GPS calibration process. Once there, itwill safely descend to the ground and poweritselfoff
; !IntelligentOrientation Control (IOC) 

# lroc is designed to help make flying more intuitive. Nominally,the yaw control will allow the Quadcopterto rotate continuouslyj [which can quickly become confusing ifyou lose trackofwhich way is "front". Suddenlyyourcontrols can get mixed up, where [pressing rightcauses the craftto move leftand pressing forward causes it move backward. IntelligentOrientation Control jprevents this from happening, keepingthe "tail" ofthe Quadcopterpointed roughlytoward the pilot at alltimes !On-Board 1080p60 Camera jup to 1080p60Video and liMP Stills The included camera systemfeatures video recording at upto 1080p60 in H.264 and also takes JPEG and DNG RAW photos at !12MP. The camera mounts via an integrated 3-axis gimbal that provides stabilization as well as pan and tilt control. Media is 'recorded internallyto a microSD card Video Resolutions and Frame Rates j1080p (1920x 1080): 24p, 2Sp, 30p, 48p, SOp, 60p j720p (1280x 720): 24p,25p, 30p, 48p, SOp, 60p 194° Wide Angle Lens The camera features a 94° angle-of-view lens, which is a narrowerangle than a fisheye for less distortion while still being !wide enough to enable capturing establishing shots. The lens features an f/2.8 aperture and is comprised of9 elements, !including an aspherical element 

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### 8/1Clf2G15 

### DJI Phantom3Advanced Quadcopterwth 1 

### 080pCameraand 3-AJQs Gimbal l

**Int\~grate..:J** 3-Axis Gimbal



# ~he gimbal provides stability by counteracting unwanted motion such as wind buffeting orvibration and also keeps the !horizon level even as the quadcopterbanks. Control dials on the transmitter (radio controller) allow you to manually pan and \tilt the camera 

# !oJI PilotAppforAndroid and iOS !Camera Control and Monitoring !View a live image with the free Pilot mobile forAndroid or iOS mobile device. The app also enables full camera control, letting !you set parameters such as camera tilt, ISO, shutterspeed, white balance as well as setvideo start/stop and take photos. The mobile device tethers to the transmittervia USB (cable available separately) ;In-App Editing and Upload !once recorded, photos and video footage can be downloaded directlyto the phone allowing them to be edited complete !with music, text, and more, and shared on Facebook, lnstagram, orothersocial media networks- even while the Quadcopter jis still in the air. Ifyou have an Internetconnection, you can even stream live to YouTube !Flight Simulator 

### '



# ~he app isn'tjustforflying. Aflight simulatorallows you to getsome practice in before taking to the skies. Aflight log allows :you to review all ofyour pastflights, with the time, duration, and even photos and videos you took ;HandheldTransmitter (Radio Controller) Included

**~ntuitive** Design 

### ' 'with sensitive control sticks, dedicated buttons, and over 1.2 mile range,the customizable Phantom 3 remote controller has !been designed to putthe controls you need where you need them. Functionality includes: !Poweron/off h'ake photos !Start/stop recording video !Gimbal control dial !Camera settings dial !Sensitive control sticks :Flight mode switch !Return Home button !USB output \Customizable buttons \Mobile device holder !Power indicators islip-free rubbermatte jMobile Device-Compatible ,Atype Afemale USB connector is provided fortethering an iOS orAndroid smartphone ortablet for live FPV monitoring and jcamera operation. A mobile device holder is included for mounting yourdevice directlyto the transmitter. Itadjusts to !accommodate both smartphones and tablets in landscape orientation 'Rechargeable Battery 

## A6000mAh LiPo battery is provided to powerthe transmitter. An AC charger is included forcharging the batterywhile in the transmitter. Four LEOs on the front ofthe transmitter indicate remaining battery life orcharge status Additional Features Intelligent Flight Battery The flight battery slots into the "tail" ofthe Phantom 3 and features and on/offswitch plus four LED charge indicators thatare !visible while flying- so you can keep trackofremaining flight time without needing to consultthe app. For recharging, balance iand power regulation is handled internallywithin the battery itself. You simply plug it into a wall outlet with the supplied :powercord and you are good to go !self-Tightening Rotors :computationalfluid dynamics (CFD) have been applied to the prop design, providing themwith increased thrust and better !efficiency compared to previous props used on earlier Phantom models. The self-tightening design helps ensure they do not jloosen in flight and not require a separate prop nut
\Maximum Speed Performance Ascent: 16.4'fps 

### I 5 m/s Descent: 9.8'

### I 3 m !HoverAccuracy Vertical: ±3.9" 

### I 10 em : Horizontal: ±3.3'

### I 1 m !MaximumAltitudeAbove Sea Level: 19,685'

### I 6000 m !FlightTime 23 minutes (depending on conditions) FlightControl System lGPS Mode GPS/ GLONASS iVision Positioning Frequency: 50 Hz
· Velocity Range: Below 26.2 fps 

### I 8 m/s (6.6'

### I 2m above the ground) Altitude Range: 11.8" to 118.1" 

### I 30 em to 300 em Operating Range: 11.8" to 118.1"

### I 30 em to 300 em Operating Environment: Surface with clear pattern and adequate lighting 

### (> 15 lux) Transmitter !Frequency 2.400to 2.483 GHz !communication Distance6561.7' 

### I 2000 m (outdoors and unobstructed) !ReceiverSensitivity 1%PER: 101 dBm ±2 dBm 

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### 214

### 8/10/2(.),15 DJI Phantom3Advanced Quadcopterwth 1080pCameraand 3-Al<is Gimbal EIRP: 20 dBm 1.2Aat7.4V )Tta(nsmitter Power \Working Current :Connectivity 1 x USB type Afemale formobile device interface IMobile Device Holder !operating Temperature 1 x Micro-USB female forfirmware updates 

### I assistant software 1 x Charge port Compatibility: Tabletorsmartphone 32to 104°F

## 1

## oto 40°C Camera Make: Sony EXMOR Size: 112.3" \Lens Resolution: 12.76 MP (12.4 MP effective) Aperture: fl2.8 FOV: 94° Focal Length: 20 mm (35 mm equivalent) Elements: 9 !Photo Resolution :rso Range Focus: 0 to oo Up to 12 MP (4000 x 3000) Video: 100to 3200 Photo: 100to 1600 !Video Resolutions tPhoto Modes 

### 1080p (1920

### x 1080): 24p, 25p, 30p,48p, SOp, 60p 

### 720p (1280

### x 720): 24p, 25p, 30p, 48p, SOp, 60p Single Shot Burst Shooting:

## 31517 shots r 'File Formats Auto Exposure Bracketing (AEB): 315 Bracketed Frames at 0.7 EV Bias Time-lapse Video: MPEG-4 AVCIH.264 in MOV wrapper (up to 60 Mbps) Photo: JPEG, DNG RAW jRecording Media Type: microSDISDXC card up to 64GB Format: FAT32 

### I exFAT 

# I Note: Class 10, UHS-1 orfaster card required .operating Temperature32 to 104°F

### 10to 40°C
· Gimbal \Number ofAxes 3-axis (pitch, roll, yaw) \Control Range -90° to +30°
1 Motor >Recommended TakeoffWeight10.6 oz 

### I 300 g peraxis \MaximumTension 1.8 lb 

### I 800 g peraxis !stator Size 0.9 x 0.5'' 

### 123 x 12 mm !MotorVelocity Constant KV: 960 rpmN iworking Temperature 23 to 104°F1-5to 40°C \Weight 1.9 oz 

### I 55 g !Chemistry >capacity Flight Battery Lithium-polymer 4480 mAh 68 Wh :configuration 45 \Voltage 15.2 VDC !weight 12.9 oz 

### 1365 g !Maximum Charging Power100 W 'operating Temperature 32 to 104°F

### I 0 to 40°C >charger Voltage: 17.4VDC 57W >Name DJI Pilot jsystem OS: iOS 8.0 or later; Android 4.1.2 or later tRequirements

### Recommended Devices: MobileApp

iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air (Wi-Fi and cellularversions), iPad mini 2 (Wi-Fi and cellular versions), iPad Air 2 (Wi-Fi and cellularversions), iPad mini 3 (Wi-Fi and cellularversions) (Note: Optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus) 

### Android: Samsung 55, Note 3, SonyXperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini Note: Additional devices may be compatible but have notyet been tested 

# I operating Temperature32 to



# 10:~'f~~\o 40°C \Dimensions Diagonal (Including Propellers): 23.2" 

### 1590 mm :weight Including Batteryand Propellers: 2.8 lb 

### I 1.3 kg



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