UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request
UAVProducts - Birdseyemedia LLC 

### 10027 Fair Oaks Goodrich, Ml 48438 517-862-1386 r obert@birdseyemedia.com
Federal Aviation Administration U.S
. Department ofTransportation Docket Management System 

### 1200 NewJerseyAve. SE Washington, DC 

### 20590

Dear Sir or Madam: Tuesday, October 6, 

### 2015

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

### 2012 (the Reform Act), UAVProducts (dba: Birdseyemedia, LLC) and owner Robert Remund hereby applyfor an exemption from Federal Aviation Regulations (FARs) detailed below to allow for commercial operations of small unmanned aerial systems for the primary purpose ofaerial photography and video. Birdseyemedia will offer safe, lowaltitude, and cost effective aerial imaging to the communities we serve. Avariety of industries will benefit; Home Real Estate, Commercial Real Estate, Marketing, Land Development, Construction, and Property Inspections. Birdseyemedia will operate a DJI Inspire 1,a small unmanned aerial system (sUAS) equipped with advanced flight control systems, high definition camera and gimbal, and advanced safetyfeatures. The sUAV will be operated by a responsible PIC (pilot in command) and VO (visual operator), in turn offering a safe and valuable experience to our clients
. UAVProducts is the original North American Distributor for OJI Innovations since 2008
. From 2008-2012 UAVProducts was the only NorthAmerican Distributor for OJI Innovations. Owner Robert Remund knows the owners of OJI Innovations on a personal basis. Owner Robert Remund is constantlytesting new products and advancing the drone industry on safety and advancements. BirdsEyeMedia, LLC and owner Robert Remund have been doing Aerial Photography from Remote Aircraft safely since 

### 2006. The experience in aerial photography and the vast background ofautopilot systems should also be noted for exemption of FARs. 1
.The OJI Inspire 1 has a maximum takeoff weight of lessthan 

### 6.5 pounds and thus offers a lightweight, small and compact video platform compared to manned aircraft. 2. The OJI Inspire 1 offers significant safety, noise, emission, security and environmental benefits not available to larger manned aircraft. 3. The OJI Inspire 1 has numerous safetyfeatures such as failsafe mode, automatic landing should signal between PIG and UAS be interrupted, GPS based altitude and distance locks, flight limiting features and low battery warnings. 4. The OJI Inspire 1 also has obstacle and avoidance feature that was just recently added as of 

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-07-2015.UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 

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5. Dual controllers provide the PIC (pilot in command) to focus on operating the sUAS while a second individual operates the camera.Two man operation is the safest setup. 6. Inspire 1safety features are addressed in more detail in the attached Inspire 1 user manual.

The safe operation ofthe UAS will be the first priority before, during and after everyoperation.
1. All sUAS operations will be conducted at Visual Line Of Sight (VLOS) at no more than 

### 200 feetAGL. 2. No sUAS operations will be conducted within 5 NM of an airport and will be in FAAclass G airspace
. 3. No sUAS operations will occur directly over densely populated areas, un-approved government buildings, power lines,or major roads. 

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. All sUAS operations will take place during daylight hours under conditions equivalent to Visual Flight Rules (VFR) with the UAS no more than 1000ft from the PIC. 5. All sUAS operations will have a PIC and VO present and all operations will be within visual line of sight (VLOS) of both the PIC and VO. 6. PIC and VO will be able to verbally communicate at all times. 7. The UAS will yield to all manned aircraft at all times
. 8. All required permits and permissions will be obtained from local and state government should they be required. 9. A pre-flight inspection bythe PI

_ C will be performed prior to each flight to assure thatthe UAS is safe for flight. A post-flight inspection will also be performed as an added level ofsafety. iO.Full aircraft inspections will be completed in accordance with manufactures instructions
. ;;.At no time shall the UAS be operated with missing or manufacturer unapproved parts, or in any condition that could pose a hazard to any other aircraft or structure or person on the gmund
. ;2. The sUAS will not be operated at a battery level below 20%. This is a safety setting in the DJI Inspire software. 

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. Priorto all UAS operations a pre-flight meeting will be held by the PIG to determinethe parameters of flight in a given location, any hazards present, weather conditions, safety procedures atthe specific location and approximate duration and route of flight. 14.The PIC will have a minimum of 10hrsflying time and operated at least 50 individual flights of similar sUAS multi-rotor aircrafts. It is my beliefthat small unmanned aerial systems, used by experienced and responsible operators, following the policies outlined above, qperating in privacy conscious way; will in turn offer aerial imagingUAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015

to the general public in ways that are more cost effective, safe,and efficientthan the traditional methods of manned aircraft. I respectfully request the FAA to grant an exemptionto Birdseyemedia LLC,for commercial UAS aerial photography operations underthe Reform Act of 2012. If any of procedures, policies, or content ofthis request do not meetthe requirements of an exemption, it is Birdseyemedia's intention to adjust its policies in accordance to the FAA's requirements outlined in the granted exemption
.

Robert Remund - Ownerof Birds emedia LLC I UAVProducts.com 10027 Fair Oaks Goodrich, Mi 48438 517-862-1386 robert@birdseyemedia.comUAVProducts - Birdseyemedia, LLC FAA333 Exemption Request Tuesday, October 6, 2015

EXEMPTION REQUESTSAND EQUIVALENT LEVELOF SAFETY Birdseyemedia LLC, requests an exemption from thefollowing regulations as well as any additional regulations that applyto the operation of OJI Inspire 1 or similar sUAS'sfor the purpose of aerial photography and video.
14 C.F.R. 61.113(a) and (b) Birdseyemedia will use speciallytrained staffto conductthe sUAS operations. While these individualswill not hold commercial pilot licenses, they will have at least 1Ohrs offlying time, have conducted at least50 individual flights and read sUAS manufactures manuals and operating procedures. In addition each PIC and VO will be required to sign a documentconfirming the understanding of Birdseyemedia operating and safety policies and the granted Birdseyemedia exemption. The sUAS will not carry propertyfor compensation or hire since they will be used solelyto provide our clients with aerial imaging. Without an exemption, the pilot would be required to hold a commercial pilot certificate under §61.133
. However,the risk associated with the contemplated operations is less than the risk posed by a traditional aircraft. The sUAS will fly at altitudes well belowthe permissible limitsfor other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelope underthe sole control of Birdseyemedia clients
. · Requiring a commercial pilot certificate would provide no appreciable safety benefit and would needlessly impose additional cost on Birdseyemedia.Becausethe contemplated operations would notcomply with §61.113(b)(1) and noneofthe other exceptionsto paragraph (a) apply, relief is needed from both paragraphs (a) and (b). 14 CFR Part2i, Subpart H: Airworthiness Certificates This part establishesthe procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for UAS, we request an experimental certificate be issued for the UAS operated bythe applicant undereither or both ofthe following provisions: 21 .191 Experimental certificates
. . Exp~rimental certificates are issued for the following purposes: Research and development. Testing new aircraft design concepts, new aircraft equipment, newaircraft installations, new aircraftoperating techniques, or new usesfor aircraft. Showing compliance with regulations
. Conducting flighttests and other operationsto show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates,flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificatecan be used for commercial purposes such as marketsurveys; sales demonstrations, and customer crew training, we would expectthat an experimental certificate would permit our commercial purpose as well. The
_ aircraft will notcarry persons or property and will onlyfly under strict operational requirements. As · Birdsyeymedia's sUAS also carries no combustible fuel, weighs lessthan 6.5 pounds and is constructed primarily of plastics and composites,we propose the UAS is at least as safe, if not significantly safer than conventionallycertified aircraft used within similar parameters. If an experimental airworthiness certificate is notappropriate for this application, then we request an exemption of ;4 CFR Part2i, Subpart H, and the requirementfor an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.lJAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015

14CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed atthe cabin or cockpit entrance so that it is legibleto passengers or crew." As the sUAS is too small to carry documentation,does not have an entrance and does not carry a crew, we propose the following in order to meetthe intent of 91.203 and provide an equivalent level of safety. All documents deemed appropriate bythe FAA for this aircraft will be located atthe operational ground station for each flight in proximity to the PIC and VO and will be available for inspection on request. In order to identifythe aircraft, we propose to use the manufacturer's model and production codes located on the aircraft as well as a Birdseyemedia logo affixed to the aircraft as well. 14 CFR 91
.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. The intent ofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. Birdseyemedia requests an exemption to this requirement as the UAS cannot, given its size, carrythe flight manual. To meet an equivalent level of safety,we propose to have the current manufacturer's flight ·· manual and the Birdseyemedia flight manual atthe operational ground station of each flight, available to both the PIC and VO. 14CFR 91.119 Minimum safe altitudes: General. The regulation provides that over sparsely populated areasthe aircraft cannot be operated closerthan 500 feet to any person, vessel, system, or structure. Since the UAS will be operating at amaximum 200 feetAGL, we.cannot comply with this requirement and thus ask for an exemption. In order to provide an equivalent level of safety, we propose the following
. The UAS will only be operated within VLOS ofthe PIC and VO at a maximum range of 1000feet from the
. ground station. A preflight safety risk assessment will be completed prior to each flight to ensure the UAS is in a condition for safe flight and thatthe planned operation can be completed safely. Birdseyemedia's Flight Manual and Pre~ Flight Checklist is included as Appendix A and Appendix B. The UAS will not be operated within 5 NM of any airport and will only be operated with the consent of property manager and/or owner. i 4 CFR 91.121 Altimeter settings. The
.regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles ofthe aircraft. The UAV will always be flying below 200 feetAGLwithin VLOS ofthe PIC and VO that will provide separation from terrain,structuresand other aircraft. Also, the UAS will continuallytransmit an AGL reading back to the controller atthe ground station and the AGL lock in the UAS's software will be setto 400 feet, providing an equivalent level of safety
. 14CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin aflightin an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after thatfor at least30 minutes. The UAS is smart battery powered and continuallytransmits battery charge information back to the ground station to be evaluated by the PIC who will return the UAS back to the ground station priorto theUAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015
batteryshowing 20% remaining capacity
. We feel thatthis combined 

### with the fact thatthe UAS 

### will have a maximum range of 1000feet from the ground station provides an equivalent level ofsafety. 14 C
.F
.R. 91.405(a), 91.407(a) (1), 14 C
.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) Maintenance, Preventive Maintenance, and Alterations. We propose that the PIC perform maintenance and inspection and "be authorized to approve the aircraft for return to service."As provided for in AppendixA, the PIC will inspectthe aircraft prior to everyflight to ensure it is in airworthy condition. A maintenance check will also be performed at intervals instructed by the manufacturer, OJI. Any general maintenance and repair or replacement of components will be completed bythe PIC following the manufacturer's recommendations and documented in accordance with 91.417. In anycase where the UAS cannot be returned to service bythe PIC,or is suspected to be unsafe, the UAS will not be operated until returned to all manufacturer specifications. We feel that dueto the simplicity, size, robustness and construction ofthe aircraft, the PIC can assure an equivalent level of safety. 8900.227 Paragraph 16(cXa) PIG Medical. and Paragraph 16(eX1) Observer Medical This policy provides that both the PIG and observer must have a valid FAA second-class medical
. certificate issued under part 67 in orderto perform as a pilot or observer. We feel that requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden. Since the UAV is ofsmall size, unmanned, has an auto return home feature, will be operating at low
.. altitudes, will notoperate over a densely populated area, and required to be in VLOS ofthe IC and VO at all times, we feel both the PIC and VO requiring vision corrected to 20/20 and a valid state issued driver's license supports medical requirements.UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015
APPENDIXA Birdseyemedia Flight Parameters and Restrictions 1. All flights will occur in FAA Class G airspace at no more than 200 feetAGL and no further than 1

### OOOft from the PIC. 2. The sUAS will not be flown faster than 40mph or as limited by FAA regulations. 3. All operations will utilize a PIC and VO with the PIC and VO able to communicate verbally at all times. 4. All operations will occur only during daylight hours and in weather conditions equivalentto VFR. 5. All operations will occur at VLOS from the PIC and VO. 6. The PIC and VO will have a pre-flight meeting at the site of the operation just priorto the flight to assess weather, area ofoperation, topography, flight time, route, hazard mitigation and overall operational and safety parameters. Also during this meeting, the pre-flight aircraft checklist (see Appendix B) will be implemented. 7. PIC is responsible for maintaining an established safe emergency landing plan if at anytime during the operation conditions become unfavorable due to unforeseen hazards, safety concerns, or weather. 8. All operations will be reviewed prior to flight and conducted with the full permission ofthe property owner or manger. 9. Flight planning will include the termination ofthe flight with 20% battery remaining, as determined by the data link between the UAS and ground station. 10. The UAV will at all times give wayto manned aircraft. 11. Prior to everyflight, a highlyvisible launch banner will be placed atthe site ofthe ground station to allow an outside observer to determine the location of the UAS's origin and command point. 12. All permits required by state and local governments will be obtained prior to any operations. 13
. No flight operations will occur without a successful pre-flight inspection by the PIC before each flight to determine thatthe UAS is in a condition for safe flight. 14. Atthe conclusion of each flight a post-flight inspection will be done to assess the condition of
. the UAS. 15
.Afull aircraft check will be performed in accordance with manufactures instructions. 16. Replacement of parts shall only be done according to manufacturer's instructions
. 17. All flight operations will be logged in a flight logbook. 18. All maintenance done and inspections performed will be lodged in a maintenance log. 19
. Check for software updates weekly and upload to UAS as needed to continually keep the UAS software
.as current as possible. ·UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015

APPENDIX B Birdseyemedia Pre-FlightChecklist 1. Ensure the area identified for flight is considered FAA Class G airspace, winds conditions are less than 15mph, and weather conditions are favorable
. 2. Identify all potential obstructions and safety hazards in or nearthe area planned for flight. 3. Inspect all propellers for proper tightness and thatthey are free of cracks, dings, chips and excessive wear. 4. Inspect all wiring and motors. 5. Inspectthe airframe for cracks ordamage. 6. Inspect batteryvoltage of UAS on-board battery and Remote Controller!Transmitter batteryto ensure there is sufficient energy in both systems for safe flight. 7. Turn off wifi wireless on all devices·located the person orwithin 10ftofthe PIC and VO. 8
. Recalibrate compass according to manufacturer's instructions. 9. Always turn on Remote Controller!Transmitter before turning on UAS battery. 10. Ensure that a link between Transmitter and UAS is established and that GPS link is established. 11. Engage throttle, lift aircraft off the ground and verify the aircraft responds properlyto all inputs and hovers accurately. 

### APPENDIXC DJIInspire 1User manual: http:/ /www.d ji.com/product/inspire-1/download