**James J. Guidici 19 Sugar Maple Ct.**  **Lake in the Hills, IL 60156 224.678.9466 (Home)**  **847.951.5448 (Cell) jim.guidici@comcast.net** 

20 May 2015

Hon. Michael Huerta Adm inistrator Federal Aviation Adm inistration U. S. Department of Transportation Docket Managem ent System 1200 New

Jersey Ave., SE Wa shington, DC 20590
Re: Summary Exem ption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from certain parts of the FARs.

Dear Adm inistrator Huerta:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Jam es J. Guidici ( or the “Petitioner”), hereby applies for a summary
exem ption from the listed Federal Aviation Regulations (“FARs”) to allow him to operate sm a ll Unm anned Aircraft System s (“ UAS”) for aerial data collection, under the conditions and lim itations set forth in this Petition.
The requested exem ption would perm it the operation of small, unm an ned and relatively inexpensive UAS under controlled conditions in airspace that is (1) lim ited, (2) predeterm ined, and (3) would provide safety enhancem ents to the already safe news gathering operations presently using m anned helicopters and airplanes. Approval of this exemption would thereby enhance safety and fulfill the FAA Administrator’s responsibilities to “...establish requirem ents for the safe operation of such aircraf t system s in the national airspace system.” Section 333(c) of the Reform Act.

The nam e and address of the applicant and his Counsel :

Jam es J. Guidici 19 Sugar Maple Ct. Lake in the Hills, IL 60156 847

- 951

- 5448 jgu idici@m e.comRegulations from which the exem ption is requested:

14 CFR Part 21 14 C.F.R. § 45.23(b) 14 CFR § 61.3 14 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2) 14 C.F.R. § 91.103 14 C.F.R. § 91.109 14 C.F. R. § 91.119 14 C.F.R. § 91.121 14 CFR § 91.151 (a) 14 CFR § 91.203 (a) & (b) 14 CFR § 91.205(b) 14 CFR § 91.215 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2) 14 CFR § 417 (a) & (b) 3
The Appendix describes the FARs from w hich an exem ption is requested and summarizes the justification for each requested exem ption.

The Petition is subm itted to fulfill Congress’ goal under Section 333(a) through (c) of the Reform Act, w hich directs the Secretary of Transportation to consider whether certain
unm anned aircraft systems m ay operate safely in the national airspace system (NAS) before
com pletion of the rulemaking required under Section 332 of the Reform Act. In making this determ ination, the Adm inistrator m ust determ ine wh i ch types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close proxim ity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator.
Reform Act § 333 (a).

If the Adminstrator determ ines that such vehicles “m ay operate safely in the national airspace system, the Secretary shall establish re quirem ents for the safe operation of such aircraft in the national airspace system.” Id. § 333(c) (em phasis added). The Secretary has delegated his aviation authority to the Adm inistrator of the FAA. The Federal Aviation Act expressly grants the FAA the au thority to grant exem ptions from its regulatory requirem ents for civil aircraft, a term defined under §40101 of the Act, w hich includes sUASs. The Administrator may grant an
exem ption from a requirem ent of a regulation prescribed under subsection (a) or (b ) of this section or any sections 44702

- 44716 of the Federal Aviation Act if Administrator finds the
exem ption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1).**Summary of Request:**

As a long time radio control pilot, I am requesting an exception, and permission to use my UAS, DJ I Phantom 2 Vision+ (further in this report are the detailed specifications of the UAS), for the purpose of taking ae rial photos and videos for the home real estat e business, and for c ommercial businesses real estate property in the suburbs of the greater Chicago area. This is a technology that is perfect for r ealtors to help the potential home buyer get a better perspective of the home and neighborhood they

are co nsidering. This is important in the rural and suburban areas, where the homes ty picall y have a larger piece of real estate, with mature landscaping, large trees, and perhaps heavily wooded. Their view of the property will be greatl y enhanced, providing f or a perspecti ve never before seen. For the c ommercial business owner, it helps them show a complete view of perhaps acres of their property for TV/Internet commercials, and /or on their websites, ie: auto dea lers, enhancing their growth opportunities. I am also planning to purchase a DJ I Inspire 1 this summer. This UAS is similar in many way s to the DJ I Phanto m Vision 2+. The differences are that is has an enhanced camera with 4K filming capability , it has landing gear that retracts, and its weight is 6.5 lbs. (the specs for this UAS are also included).

**Why the exemption would not adversely affect safety:**
This can be done very

safely in a controlled environment, on private property , with limited airtime required, extremely

low noise, in uncongested areas. The UAS will alway s be operated in a Visual Line of Sight (VLOS) environment, with an observer, and alway s under 400 feet.
Prior to flight, I go through a “pre

- flight” checklist: 1. verify	propellers	are	properly	secured	and	not	damaged. 2. ensure	all	b atteries	are	fully	charged

a. UAS	battery b. Transmitter/controller	battery

c. Wi

- Fi	range	extender	battery 3. turn	on	transmitter	&	range	extender 4. turn	on	UAS	battery 5. initiate	a	“calibration”	procedure	for	the	Compass 6. place	UAS	in	a	safe	position	on	the	ground	for	t akeoff 7. turn	motors	on 8. verify	there	are	6	or	more	satellites	acquired 9. initiate	takeoff 10. hover	at	10

– 15	feet	and	verify	all	controls	are	operating	properly 11. initiate	flight	plan 12. upon completion	of	flight	plan,	ensure	a	safe	environment	exists	for	a	safe	landing,	and inspect	UAS	prior	to	another	flight	for	air	worthiness**Description of UAS:**

The DJ I Phantom Vision 2+ (UAS) operates on 5.8 GHz, and weighs 2.7 pounds. Serial # BF1613340486263. Ithas a very sophisticated flight control s ys tem (DJ I NAZA

–M V2), and includes a Gy

ro, Compass, GPS, and camera that is on a three axis gimbal. The flight s ys tem includes a “Failsafe” function, where if signal is lost, or interferenc e occurs with the controller, or it fly ’s out of range, the UAS will automatically return to its “home” position. It also provides altitude & radius flight adjustment settings, for maximum height and distance.

It will also “altitude hold

- auto hover” i f radio control sticks are released. And, i n order to increase flight safety

and prevent accidental flights in restricted areas, the new firmware for the Phantom 2 series includes a “No Fly Zone ” feature. These zones have been divided into two categories : A

- large international airports and, B

- small local airports. http://www.dji.com/fly

- safe/category
Exceeding the control range of the remote control will trigger ‘Return

- to

- Home’, meaning the Phant om 2 Vision+ will automatically fly back to its takeoff point and land safel y.
Using Wi

- Fi and a Wi

- Fi Range Extender, the camera transmits live video to my Apple iPhone 6 or iPad Mini 2, all of which comply with FCC requirements. The DJ I Vision App sh ows, altitude, direction of flight, distance from home, speed, location, number of satellites acquired, and battery level.
**Pilot in Command (PIC) Background and experience:** 

I have 30 years experience in flying radio control UAS aircraft, and have been fl yi ng radio control ai rplanes since the mid 80’s. My current inventory tota ls 30 electric aircraft, including fixed wing prop planes, mostly WWII war birds, EDF (electric ducted fan) jets, and multi

- copters. I am a Viet Nam veteran, USAF, and I am currently retired from the technology industry

. I have alway s been intrigued with any ne w technology , and generall y have alway s been an earl y adopter.

I am a member of the Academ y of Model Aeronautics, with a very good understanding of aeronautics, and I have alway s been an extremel y responsible UAS pilot. Iam in great health. Being retired, and on a fixed income, I would like to take advantage of m y hobby skills, in a commercial way , to help generate additional revenue for living expenses. I have be en into video and photograph y, as a hobby , m y entire life. This new technology ties togeth er, both of my long time hobbies

. I am c urrently in process of getting my Sport Pilot Certificate, and I hold a valid drivers license from the S tate of I llinois.

**W hy the p**  **ublic would be served by granting this exemption:**

I believe this is a technology that can benefit realtors and c ommercial businesses, in a huge way

. The industry

is anxious to have this technology enhance their ability

to market properties from a totally new perspective, because the aerial perspective is very impressive. By

increasing their marketing potential it can increase home sales, benefiting Realtor, buyer and seller. That is a win, win, win. For the c ommercial business owner, that new a erial perspective can increase market awareness and growth, with greater recognition of business message, phys ical presence, inventory (in the case of an auto dealer) and location.The Petition to use a UAS for aerial data collection and its proposed l imitations are similar in all

material respects to those approved b y the FAA in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA −2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No . FAA−2014−0382), 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642) and 11310 to Colin Hinkle (see Docket No. FAA

- 2014

- 0608). In those grants the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications de scribed b y the Petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled b y this exemption is in the public interest.

The reasons stated b y the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213, and 11310 also apply

to the situation presented by this Petition.
Respectfully

Submitted,

James J. GuidiciAPPENDIX

FAR section Subject Justification 14 CFR § 45.23(b) Requirement to display registration number on vehicle Insufficient space on vehicle

14 CFR Part 21 Aircraft certification requirements and procedures Designed for manned aircraft; not suitable for off

the

- shelf UAS 14 CFR § 61.3 Requirement for pilot certificate Part 61 requirements designed for manned aircraft, not UAS; p etition describes training for UAS operator 14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; not suitable for off

the

- shelf UAS 14 CFR § 91.9 (b) (2) Requirement for manual to be available in the cockpit No one aboard to read manual 14 CFR § 91.103(b) Requirement for crew members to be onboard Unmanned vehicle

14 CFR § 91.109 Requirement for dual controls during flight instruction No one aboard to operate controls

14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation below these altitudes 14 CFR § 91.121 Altimeter settings No one aboard to read altimeter 14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 14 CFR § 91.203 (a) & (b) Requirement for registration and airworthiness certificates to be onboard No one aboard to read certificate s

14 CFR § 91.205(b) Cockpit instruments No one aboard to read 14 CFR § 91.215 Transponder requirement Vehicle has insufficient useful load; will be operated below ATC radar coverage 14 CFR § 91.405 (a) Inspection requirements Designed for mannedaircraft; not suitable for off

the

- shelf UAS 14 CFR § 91.407(a) (1) Inspection approval requirements Designed for manned aircraft; not suitable for off

the

- shelf UAS 14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft; not suitable for off

the

- shelf UAS 14 CFR § 91.417 (a) & (b) Maintenance records requirements Designed for manned aircraft; not suitable for off

- the

- shelf UASFurther details of the DJ I Phantom Vision 2+, and a PDF of the manual can be viewed

and downloaded here: http://www.dji.com/product/phantom

- 2

- vision

- plus B uy N o w 

## Aircraft Supported Battery DJI 5200mAh LiPo Battery Weight (Battery

& Propellers Included) 1242g Hover Accuracy

(Ready To Fly) Vertical: 0.8m; Horizontal: 2.5m Max Yaw Angular Velocity 200°/s Max Tiltable Angle 35° Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s Max Flight Speed 15m/s (Not Recommended) Diagonal Motor

- Motor Distance 350mm 

## Gimbal Working Current Static : 750mA; Dy

namic : 900mA Control Accuracy ±0.03° Controllable Range Pitch :

- 90°

-

0° Maximum Angular Speed Pitch : 90°/s 

## Cam era Operating Environment Temperature 0

- 40 Sensor Size 1/2.3" Effective Pixels 14 Megapixels Resolution 4384×3288 Hd Recording 1080p30 & 720p Recording Fov 110° / 85°

## Remote Control Operating Frequency 5.728 GHz

-

5.85 GHz Communication Distance (Open Area) CE Compliance: 400m; FCC Compliance: 800m Receiver Sensitivity

(1%Per)

- 93dBm Transmitter Power CE Compliance: 25mW; FCC Compliance: 100mW Working Voltage 120 mA@3.7V Built

- In Lipo Battery

Working Current/Capacity 3.7V, 2000mAh 

## Range Extender Operating Frequenc y 2412

- 2462MHz Communication Distance (Open Area) 500

- 700m Transmitter Power 20dBm Power Consumption 2W 

## DJI VISION App Sy stem Requirement Of Mobile Device iOS version 6.1 or above/ Android sy stem version 4.0 or above Mobile Device Support

• iOS recommended: iPhone 4s, iPhone 5, iPhone 6,

• iPhone 6 Plus

• iP od touch 5 (available but not recommended:

• iPad 3, iPad 4, iPad mini)

• Android recommended: Samsung Galaxy S3, S4,

• Note 2, Note 3 or phones of similar configurationThese are the specifications for the DJ I Inspire 1.

http://www.dji.com/product/inspire

- 1



## Aircraft Model T600 Weight (Battery

Included) 2935 g Hovering Accuracy

(Gps Mode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Flight Altitude 4500 m Max Wind Speed Resistance 10 m/s Max Flight Time Approximately

18 minutes Motor Model DJI 3510 Propeller Model DJI 1345 Indoor Hovering Enabled by

default Operating Temperature Range

- 10° to 40° C Diagonal Distance 559 to 581 mm Dimensions 438x451x301 mm

## Gimbal Model ZENMUSE X3 Output Power (With Camera) Static: 9 W In Motion: 11 W Operating Current Station: 750 mA Motion: 900 mA Angular Vibration Range ±0.03° Mounting Detachable Controllable Range Pitch:

- 90° to +30° Pan: ±320° Mechanical Range Pitch:

- 125° to +45° Pan: ±330° Max Controllable Speed Pitch: 120°/s Pan: 180°/s 

## Cam era Name X3 Model FC350 Total Pixels 12.76M Effective Pixels 12.4M Image Max Size 4000x3000 Iso Range 100

- 3200 (video) 100

- 1600 (photo) Electronic Shutter Speed 8s

- 1/8000s Fov (Field Of View) 94° Cmos Son y EXMOR 1/2.3” Lens 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups Anti

- distortion Still Photography

Modes

### Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Time

- lapse Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate Of Video Storage 60 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264) Supported Sd Card Types Micro SD Max capacity : 64 GB. Class 10 or UHS

- 1 rating required. Operating Temperature Range 0° to 40° C 

## Remote Controller Name C1 Operating Frequency 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2.483 GHz Transmitting Distance (Outdoor And Unobstructed) 2 km Eirp 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port USB, mini

- HDMI Power Supply Built

- in battery Charging DJI charger Dual User Capability Host

- and

- Slave connection Mobile Device Holder Tablet or Phone Max Mobile Device Width 170mm Output Power 9 W Operating Temperature Range

- 10° to 40° C

### Storage Temperature Range Less than 3 months:

- 20° to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0

- 40° C Battery 6000 mAh LiPo 2S 

## Charger Model A14

- 100P1A Voltage 26.3 V Rated Power 100 W 

## Battery (Standard) Name Intelligent Flight Battery Model TB47 Capacity 4500 mAh Voltage 22.2 V Battery T yp e LiPo 6S High voltage battery Energy 99.9 Wh Net Weight 570 g Operating Temperature Range

- 10° to 40° C Storage Temperature Range Less than 3 months:

- 20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range 0° to 40° C Max Charging Power 180 W 

## Battery (Optional) Name Intelligent Flight Battery Model TB48 Capacity 5700 mAh Voltage 22.8 V Battery T yp e

### LiPo 6S Energy 129.96 Wh Net Weight 670 g Operating Temperature Range

- 10° to 40° C Storage Temperature Range Less than 3 months:

- 20 to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0° to 40° C Max Charging Power 180 W 

## Vision Positioning Velocity Range Below 8 m/s (2 m above ground) Altitude Range 5

- 500 cm Operating Environment Brightly lit (lux > 15) patterned surfaces Operating Range 0

- 250 cm 

## DJI Pilot App Mobile Device Sy stem Requirements iOS 8.0 or later Android 4.1.2 or later Supported Mobile Devices * Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus iPad Air, iPad Air Wi

- Fi + Cellular, iPad mini 2, iPad mini 2 Wi

- Fi + Cellular, iPad Air 2, iPad Air 2 Wi

- Fi + Cellular, iPad mini 3, and iPad mini 3 Wi

 Samsung S5, Note 3, Sony Xperia Z3, Google

 Nexu s 7 II, Google Nexus 9, Mi 3, Nubia Z7

 mini *Support for additional Android devices available as t t esting and development continues