June 19, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation .: t)

Regulations from: 14 CFR 21 subpart H; 14 CFR45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, Tydon Davis Kommel, DBA "Aeris Imaging," operator ofthe 3D Robotics Iris+ Unmanned Aircraft System (UAS), hereby applies foran exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofdesignated UAS, provided such operations are conducted within and underthe conditions outlined herein oras may be established bythe FAAas required by Section 333. Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 1. Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/orphotographyfor public and/or private use including television, public events, cinematography and newsgathering. 3. Aerial inspection/photography of residential/commercial structures undercontractwith the owners or local government authority. 4. Aerial inspection/photography ofresidential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergencyor natural disaster onlywhen the local authorities or government has requested it by contract ordonation.6. Training to persons individually or belonging to both private and/or public organizations to increase awareness and improve safetyfor current and future UAS operationswithin the NAS. As described fully below, the requested exemptionwould permitthe operation ofdesignated UAS as setforth in this document undercontrolled conditions in the NAS thatwould be a) limited b) controlled c) predetermined and d) safe. Approval ofthis exemption would increase public awareness of UAS operations and enhance safetyto aid in fulfilling the Secretary of Transportation's (the FAAAdministrator's) responsibilities to "

....establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant is: Tydon Davis Kommel, DBA "Aeris Imaging" Ph: 

### 818.723.3909 Email: tydon@aerisimaging.com Address: 

### 9725 Owensmouth Ave., Chatsworth, CA

### 91311 Regulations from which the exemption is requested: 

### 14 CFR Part

### 21 subpart 

### H 14 CFR

### 45.23 (b) 

### 14 CFR 

### 61.113 (a) & (b) 

### 14 CFR 

### 91.7 (a) 

### 14 CFR 

### 91.9 (b) 

### (2) 14 CFR

### 91.103 14 CFR

### 91.109 14 CFR 

### 91.119 (c) 

### 14 CFR 

### 91.121 14 CFR 

### 91.151 (a) 

### 14 CFR 

### 91.203 (a) & (b) 

### 14 CFR 

### 91.405 (a) 

### 14 CFR 

### 91.407 (a) 

### (1) 14 CFR 

### 91.409 (a) 

### (2) 14 CFR 

### 91.417 (a) & (b)

### Tydon Davis Kommel, DBA "Aeris Imaging", will operate one or more ofthe following model UAS: 1. 3D Robotics Model Iris+ with the following specifications:

• Iris+ Aircraft o 

### Flighttime • 15 minutes o 

### Height • 100mm o 

### Diagonal Length Without Rotors Installed • 550mm o 

### Propellers • 9.5 x 4.5 selftightening propellers o 

### Weight Without Battery and Payload • 2.83 pounds o 

### Weight With Battery and Payload • 3.46 pounds o 

### Battery • 3S 11.1 volt 51OOmAh 8C Lithium Polymer pack o 

### Charger • 3S 11.1 volt Lithium PolymerAC/DC Intelligent Balancing charger o 

### Transmitter • 9 channel 915MHz

• Tarot 2D Gimbal Stabilization System o 

### Cameras supported • GoPro HER03 • GoPro HER03+ • GoPro HER04 o 

### lnpuUOperating Voltage • 7.4V-14.8V DC o 

### Current Consumption • 200mA-500mA o 

### Working Environment Temperature • -15 °C to 65

## oc o 

### Weight Without Camera • 0.44 pounds o 

### Weight With GoPro HER03 • 0.6 pounds o 

### Weight With GoPro HER04 • 0.63 pounds• 3D Robotics GoPro Live View Kit o Operating Frequency • 5.8GHz o Receiver • 2 antenna diversity • 1 cloverleaf antenna • 1 omnidirectional antenna o LCD Screen • 7" high definition LCD • 11OOmAh rechargeable Li-lon battery o Transmitter • 5.8GHz with cloverleafantenna Given the small size ofthe UAS in scope and the controlled environment provided, the proposed operations will adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests that the FAAgrantthe requested exemption. AIRCRAFTAND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as setforth in the Flight Operations Manual (FOM) include: 1. The UASwill weigh significantly lessthan 55 lbs. Itweighs lessthan 4 pounds with battery and camera. 2. The UAS, depending on the model in operation, will have a maximum operating speed of no more than 70 MPH. 3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). 4. Maximum flight time for each operational flight will be depending on the UAS model in operation, butwill not exceed 15 minutes. Flights will be terminated at25% battery power reserve or 15 minutes offlight time whichever occurs first.5. Flights will be operated at an altitude of no more than 400 feetAbove Ground level (AGL) and not more than 200feet above an elevated platform from which filming is planned. 6. Minimum crewforeach operation will consist ofthe UAS Pilot and at least one Visual Observer (VO), and may include a third, butseparate, Camera Operator (CO). 7. The UAS pilot will be a designated Pilot in Command (PIC)

. The PIC will have logged a minimum of20 hours on the designated UAS. 8. A safety briefing will be performed priorto each day's flights consisting ofall the days' production activities. 9. All flight activities will be logged. 10. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only. 11. Theflights will occur in Class G airspace no closerthan a Smile radius ofthe geographic center/Airport Reference Point (ARP) ofa towercontrolled or uncontrolled airport. 12. Flights will not be closer than a 5 mile radius ofthe geographic center/Airport. 13. The operatorwill file FAA Form 77111, or its equivalent, as modified in light ofthe requested exemption, with the appropriate local Flight Standards District Office (FSDO) no morethan 72 hours but no less than 48 hours from planned operation. 14. The operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as U.S. Department ofTransportation required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved. 15. The PIC and VOwill have been trained in operation of UAS and receive up to date information for the particular UAS to be operated. 16. The PIC and VO will be able to communicate byvoice and/or radio at all times. 17. Written and/orverbal permission and permits will be obtained from territorial, state, county or cityjurisdictions, including lawenforcement, fire orother appropriate governmental agencies as appropriate to flight operations. 18. Ifthe UAS loses communications with the remote controlleror loses GPS signal, the UAS will have the capability to return to a predetermined location within a designated location and land autonomously.19. The UAS will have the capabilityto abort a flight in case ofemergencies with an automated "Return Home" and "Land" function. 20. The UAS will have the capabilityto abort a flight in case ofunpredicted obstacles, weather, oremergencies such as low battery. THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 Aeris Imaging submits thatgrant ofthis exemption application for use ofthe Iris+ in precision aerial surveying, inspection, videography and photographywill advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate the introduction of UAS's into the national airspace system ("NAS") if it can be accomplished safely. This lawdirects the Secretary ofTransportation to considerwhether certain UASs may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users ofthe NAS orthe public or pose a threatto national security in light ofthe following:

• The UAS's size, weight, speed, 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)(1). Ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." ld. §333(c). The Federal Aviation Act expressly grants the FAAthe authorityto issue exemptions. This statutory authority, by itsterms, includes exempting civil aircraft, as the term is defined under §40101 oftheAct, from the requirementthat all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The grant ofthe requested exemption is in the public interest based on the clear direction in Section 333 ofthe Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to UAS'sfor aerial surveying, photography, inspection and videography. Accordingly, the applicant respectfully requests that the FAA grantthe requested exemption without delay as these are services desperately needed in the California area dueto drought issues.Grant ofthe exemption to Aeris Imaging will be subjectto the following mandatory conditions, which are based upon operating conditions setforth foroperation of UAS by public entities pursuantto Certificates ofAuthorization, with additional restrictions:

• All operations to occur in Class G airspace • Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts • Operationsto be conducted over private orcontrolled-access property • Permission from land owner/controller required before commencing any flight • Operations to occur during Visual Flight Rules Meteorological Conditions (VMC) • Aircraftto remain within Visual Line ofSight (VLOS) o VLOS guaranteed with a cylinder ofoperation around operator of% nautical miles (NM) o Cylinderwalls may be expanded by additional observer's • Operations to occurduring daylight hours • Above Ground Level (AGL) altitude to be restricted to 400 feet • All operations conducted in vicinity ofairport to remain morethan 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds • All required permissions and permitswill be obtained from territorial, state, county orcity jurisdictions, including local law enforcement, fire, orother appropriate governmental agencies Operator Requirements Aeris Imaging respectfully proposes that operator requirements should take into accountthe characteristics ofthe particular UAS. Certain UASs, such as the Aeris Imaging Iris+, are characterized by a high degree ofpre-programmed control and various built-in technical capabilities that limitthe potential for operation outside ofthe operating conditions set forth above. The Iris+ has a semi-autonomous navigation and control system comprised ofa Ground Control Station (GCS), GPS stabilization and auto-pilot system. In the case ofunplanned events, the operator can allowthe aircraft to follow the pre-programmed evasive maneuversfrom the control unit orenable assisted steering fordirect control. Pre-programmed maneuvers include initiation ofholding at present position; suspension ofmission; fly backto launch point; fly to point and hold; abort mission and land; and emergency power cut offand land (Flight Termination System). Additional automated safetyfunctions and safety enhancing features ofthe Iris+ include the following:

• Detection oflost GPS signal will initiate a return to launch program, allowing the operatortime to take control ifnecessary.• The GCS produces an audible message ofthe battery level every 

### 15-60 seconds (this can be adjusted). At 

### 10.2V (this can be adjusted) overall packvoltage the aircraftwill automatically land. • On-board failsafe limits aircraft descent speed to a maximum ofapproximately 5 m/s. • The aircraft, weighing less than 4 lbs, fully loaded, is constructed of high impact plastic orsimilar material which is intended to absorb impact energy. • The motor is driven bya pulse width modulated signal, not an analog signal. In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to allow commercial operations ofa small unmanned vehicle conducting aerial imaging, photography, videography, inspection and surveying. Approval ofthe exemption allowing commercial operations ofthe Iris+ for aerial imaging, photography, videography, inspection and surveying workwill enhance safety by reducing risk. Conventional aerial operations, usingjet or piston-powered aircraft present risks associated with vehicles thatweigh in the neighborhood of

### 5,000to 

### 7,000 lbs, carry large quantities offuel, passengers, and, in some cases, cargo. Such aircraft mustfly to and from the survey location. In contrast, an Iris+ weighing less than 4 lbs and powered by batteries eliminates a portion of that risk given the reduced mass and lack ofcombustible fuel carried on board. The Iris+ is carried to the survey location, notflown there. The Iris+ will carry no passengers orcrew and, therefore, will not expose any individuals to the risks associated with manned aircraftflights. The operation ofthe Iris+, weighing less than 41bs, for aerial imaging, photography, videography, inspection and surveying in accordance with the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting Aeris Imaging from the requirements of Part 

### 21. The lris+'s satisfaction ofthe criteria setforth in Section 

### 333 ofthe Reform Act-size, weight, speed, operating capabilities, lack ofproximity to airports and populated areas, operation within visual line ofsight, and national security-and its showing ofan equivalent level ofsafety as it may relate to the requirement for a pilot's license, provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofthe Iris+ in the commercial precisionvideo and imaging business. Sincerely, 

# I

1./L.__.--- Tydon D. Kommel OwnerofAeris Imaging 

### 9725 Owensmouth Ave. Chatsworth, CA

### 91311 818-723-3909