**IN THE MATTER OF THE PETITION FOR EXEMPTION OF: EYE**  **- IN**  **- THE**  **- SKY AERIAL PHOTOGRAPHY LLC**  **FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF**

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151(a)**  **91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)**

Submitted on 04/29/2015 By : David T. and Denise G. Hilton Eye - in - the - Sky

Aerial Photography LLC (352) 796 - 9633**P ETITION**  **FOR RELIEF**  **OF REQUIREMENTN**  **OF TITLE**  **14 OF**  **THE CODE** 

**OF FEDERAL**  **REGULATIONS, SPECIFICALLY**  **AS AUTHORIZED**  **UNDER THE**  **F.A.A. MODERNIZATION**  **AND REFORM**  **ACT OF**  **2012, SECTION**  **333; SPECIAL RULES FOR CERTAIN UNMANNED AIRCRAFT SYSTEMS.**  **David T**  **. Hilton**  **and Denise**  **G. Hilton**  **, DBA**  **as Eye**  **- in**  **- the**  **- Sky**  **A erial**  **P hotography**  **LLC** Eye - in - the - Sky

A erial Photography LLC seeks exemptions from Title 14 of the Code of Federal Regulations: 61.113 (a) and (b); 91.7 (a); 91.119; 91.121; 91.151.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b) , in order to operate a **Y u**  **neec Typhoon**  **500Q+ UAS**  . This exemption will allow Eye - in - the - Sky A erial Photography LLC to operate an unmanned aerial vehicle commercially f or the purpose s of conducting aerial video and still photogra phy in the Real E state , Insurance and C onstruction markets of Florida and Georgia . These still images and videos will provide both commercial and community awareness and understanding of aerial imaging s ys tems . Eye - in - the - Sky

A erial Photography LLC is a real estate , insurance and survey aerial photography company producing high quality results for client s who want to display images both for real estate and insurance documentation and survey purposes throughout the southern Florida and Georgia market s. Eye - in - the - Sky A erial Photo graphy

LLC will be using a Yuneec Ty

phoon 500 Q + quad cop ter to commerciall y capture video stills and film while working on private and public properties for the purpose of aerial location services . Eye - in - the - Sky A erial Photography LLC will employ b oth a licensed pilot and utilize a visual observer to maintain a visual line - of - sight between the quad copter and the pilot UAV operator , who will hold, at minimum, a current private pilot’s license . **THE YUNEEC TYPHOON 500 Q+**  The Yuneec T yphoon 500 Q + is an electric powered quad copter weighing less than three pounds and is operated via a handheld remote that features “Return to H ome ” and “F ollow M e ” commands. The Return to H ome feature can be triggered manually and the UAV unit works off of a 2.4 GHz downlink for remote control . The video function works on 5.8 GHz frequency

video. The default altitude setting for the Typhoon 500 Q + is 40 0 feet AGL. The camera system is a CG 02 and is operated from the handheld remote control . B oth units are powered by a s ingle battery

giving the Ty

phoon 500 Q + approximately

25 minutes of flight time.**B ASIS FOR PETITION** 

Eye - in - the - Sky

A erial Photography LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. SS 11.61) and the F . A . A . M odernization and Reformed A ct of 2012, S ection 333, Special R ules for C ertain Unmanned Aircraft S ys tems , hereb y petitions the Administrator to operate the TYPHOON 500 Q+ UA S within the National Airspace S ys tem , and for an exemption from the requirements of 14 CFR SS 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) (1) , 91.409 (a) (1) and (2), 91.417 (a) and (b) . **N AME AND**  **ADDRESS OF THE PETITIONER**  David T. Hilton / Denise G. Hilton Eye - in - the - Sky

Aerial Photography LLC 5264 Em ers on Rd . Brooks ville , F lorida 34601 dthilton@hotmail.com **EYE -** **IN -**  **THE -**  **SKY AERIAL**  **PHOTOGRAPHY LLC**  **Request s**  **Relief from**  **the Following S**  **ections of 14 C .**  **F .**  **R.**

 Sections 61.113, entitled Private pilot privileges and lim itations: Pilot in C ommand , Subsections (a) and (b) .  Section 91.7, entitled Civil airworthiness subsection ( a) .  Section 91.119 entitled M inimum S afe A ltitudes, General .  Section 91.121, entitled A ltimeter S ettings .  Section 91.151 entitled F uel requirements for flight in VFR conditions .  Section 91.405, entitled M aintenance required.  Section 91.407 (a) (1), entitled O peration after maintenance, preventative maintenance, rebuilding, or alteration.  Section 91.409 entitled Inspec tions .  Section 91 the .417 entitle d M aintenance R ecords . Extent of relief that Eye - in - the - Sky A erial Photography LLC seeks regarding section 61.113 (a) and (b) Private pilot privileges and limitations : Pilot in Command, Subsections (a) and (b) prescribed the following, in part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft

in connection with any business or employment if

–(1) The flight is onl y incidental to that business or employment and (2) The aircraft does not carry p assengers or property for compensation or hire. Relief from section 61.113 (a) and (b) is requested to allow a PIC holding a current private pilot’s certificate to operate the Ty phoon 500 Q +. The flight would be complemented by

a visual observer who will , along with the pilot , maintain visual line of sight with th e Typhoon 500 Q + at all times . All operations will be conducted as per Eye in - the - Sky

A erial Photography

LLC’s business related operations. The T yphoon 500 Q + is not able to carry

passengers . Extent of relief that Eye - in - the - Sky A erial Photography

LLC se eks in regards to section 91.7(a) , Civil Airworthiness ; Relief from section 91.7(a), is requested to allow Eye - in the - Sky Aerial Photography

LLC to determine the air worthiness of the T yp hoon 500 Q + . Extent of relief that Eye - in - the - Sky A erial Photography LLC seeks in regards to section 91.119, Minimum Safe A ltitudes ; General . Relief from 91.119 is requested to allow operations of the Typhoon 500 Q + at altitudes not to ex ceed 400 feet AGL , over private property or at a distance at or greater than five nautical miles from the nearest airport as depicted on current aeronautical charts. Eye - in - the - Sky

A erial Photography

LLC also wishes to be granted exemptions to operate at an altitude not more than 50 feet AGL or below tree level between one and five nautic al miles from the nearest airport as depicted on current aeronautical charts. Extent of relief that Eye - in - the - Sky Aerial Photography

LLC seeks from 91.121, (a) , Altimeter S

ettings Extent of relief from 91.121 is requested because the T yphoon 500 Q + utilizes an Electronic GPS with a barometric sensor. Extent of relief that Eye - in - the - Sky A erial Photography LLC seeks in regard to section 91.151(a), F

uel R equirements for F

light in V FR C onditions . Relief from 91.151(b), is requested to the extent that allows Eye - in - the - Sky A erial Photography LLC to operate the T yphoon 500 Q + up to a point that there is enough power to fl y at normal cruising speed to the landing point and land the vehicle with 25% battery p ower remaining. Note : a low battery alarm on the operating console for the Typhoon 500 Q + is e quipped with a shaker mechanism to warn the pi lot of a low battery condition.Extent of relief that Eye - in - the - Sky A erial Photography LLC seeks in regards to sections 91.405(a), 91.407(a)(1), 91 .409 point(a)(1) and (a)(2), 91.4179 1.417 ( a) and (b ). These are all associated with an airworthiness certificate. There are currentl y no airworthiness certificates for small UAVs. **B ENEFITS**  **GAINED V** **I A**  **RELIEF FOR**  **EYE -** **IN -**  **THE -**  **SKY AERIAL**  **PHOTOGRAPHY LLC from the abo**  **ve stated Federal Regulations:** A. Use of the small UAV will allow for quicker and timelier aerial mapping , aerial surveying and aerial photography of properties as contracted for. B. Use of the small UAV will allow for more cost effective aerial mapping and surveying as the cost to operate a small UAV is fractional compared to the cost of operating a full size aircraft for aerial photography. C . Use of the small UAV will lesson the use of full size aircraft for some aerial photography missions and theref ore give a somewhat greater safety ratio for the use of aerial photography. **R EASONS WHY SAFETY WILL NOT BE AFFECTED BY GRANTING THESE**  **REQUESTED EXEMPTIONS:**

 S tandard operating procedures prior to launch will include a preflight checklist of the vehicle and a visual inspection of area to be surveyed at ground level will be performed .  Flight operations will be conducted by atwo man crew consisting of the PI C and the Visual Observer. All operations will be conducted with a clear line of sight between the UAV and the team.  Eye - in - the - Sky

A erial Photography LLC will only operate the UAV over private or public property with the permission of the property owner or the governing body and will maintain a safe distance from any structures , people or vehicles. This petition is being made pursuant to the FAA M oderni zation and Reform Act of 2012, S ection 333, which directs the Secretary o f Transportation to determine if any UAS m ay safel y operate in the National Airspace. The petitioner, David T. Hilton, currentl y hold s a single engine land , private pilot’s license and a third class medical and will be the primary PIC in command of the T yphoon 500 Q + . Eye - in - the - Sky

A erial Photography LLC will operate all aircraft granted for use by the exemption as directed by th e operating manual provided with the Typhoon 500 Q + by the manufacturer.**IN CONCLUSION** 

As set forth previously Eye - in - the - Sky A erial Photography LLC seeks an exemption pursuant to 14 CFR: 11 .61 and Section 333 of the FAA Modernization and Reform A ct of 2012, which will permit safe operation of Ty phoon 500 Q + UAS commerciall y within the insurance , real estate and construction markets. The Administrator will be assisting small business by

granting this petition. Respectfully

submitted by Eye - in - the - Sky A erial Photography LLC . David T Hilton / Denise G. Hilton Submitted on 04 - 29 - 2015 352 - 796 - 9633 727 - 514 - 3838 dthilton@hotmail.com